Do you know everything you need to know about the 10 most frequently cited Occupational Health and Safety Administration standards? In this series, we’re exploring the most common OSHA violations, one by one. Keep reading to learn about OSHA’s machine guarding requirements.
OSHA Machine Guarding: What It Is
OSHA definition: “Employee exposure to unguarded or inadequately guarded machines is prevalent in many workplaces. Consequently, workers who operate and maintain machinery suffer approximately 18,000 amputations, lacerations, crushing injuries, abrasions, and over 800 deaths per year. Amputation is one of the most severe and crippling types of injuries in the occupational workplace, and often results in permanent disability.” (Source)
Simple definition: Industrial equipment is dangerous. Machines such as power saws, shears, guillotine cutters, presses, milling machines, fans, conveyor belts, palletisers and revolving drums can slice, crush, and tear off workers’ body parts. Sometimes, hazards are caused by nip points (also called pinch points)—points where one or more parts (such as gears) rotate. In other cases, machines generate sparks or flying chips that can injure workers.
For these reasons, OSHA requires that certain pieces of equipment have specific protection mechanisms in place. This is what’s known as machine guarding. Examples of machine guarding include barriers, light curtains, and two-hand trips.
Machine guarding typically applies to the point of operation—that is, the location on or near the machine where work is performed. However, many machines need to be safeguarded at multiple points. Additionally, there are plenty of instances where OSHA requires or recommends secondary controls, such as alarms and fences.
Why OSHA Machine Guarding Violations Happen
The danger posed by machines may seem obvious, and yet accidents and incidents happen frequently. In fact, machine guarding violations are one of the most commonly cited OSHA standards.
Why do so many machine guarding violations occur? One reason is that not all equipment has required safety controls in place. While most single-purpose machines provide point-of-operation and power transmission safeguards as standard equipment, not all machines in use have built-in safeguards provided by the manufacturer. Perhaps safeguards have been removed because they got in the way or the nature of the work changed. Or maybe, as is the case for many older machines, safeguards simply weren’t there to begin with.
Sometimes, where there aren’t built-in safeguards, users will construct and design their own safeguards. Unfortunately, user-built guards have disadvantages—they may be poorly designed or built, or may not conform well to the configuration and function of the machine.
Regardless of the type of guard in place, countless machine guarding accidents result from human error. Workers rush or become careless and overlook safety precautions. Sometimes, people make the wrong decisions in moments of panic—a supervisor may shut power off while someone is still using a machine, for instance, or an operator may press the wrong button. Stress can cause or exacerbate these issues.
Finally, as with virtually all OSHA violations, inadequate training is a leading cause for accidents.
What You Stand to Lose When Machine Guarding Violations Happen
Direct costs: OSHA penalties can exceed $13,000 per violation—and as much per day for every day the issue hasn’t been fixed by OSHA’s deadline. The fine for a willful or repeated violation can be 10 times as much.
- workers’ compensation claims from workers who sustained amputations, cuts, abrasions, or other machine-caused injuries
- lost productivity due to injuries
- expenses related to replacing safeguards or installing missing ones
- expenses related to replacing damaged equipment
- legal and compliance fees
- decreased morale
- negative publicity and reputational damage
Signs You’re at Risk of Machine Guarding Violation
You work with numerous industrial machines: The more pieces of dangerous equipment you have around, the higher your risk of a machine guarding-related accident or violation.
You have one or more decades-old machines still in operation: Equipment manufactured in the 1990s, 80s, 70s, or earlier isn’t always in line with OSHA’s rules and standards. (Note that newer equipment isn’t necessarily risk-free, however. In 2017, OH&S Online conducted machine surveys for “a new mill drill and drill press from leading machine manufacturers” and found that both machines were in “dire non-compliance new out of the box.”)
You haven’t inspected your machines recently: Organizations need conduct frequent risk assessments and surveys of their equipment.
People are working close to hazardous machines: One basic form of machine guarding is called “guarding by location.” According to OSHA, this “involves positioning or designing a machine so that the hazardous parts are away from areas where employees work or walk, or alternatively, installing enclosure walls or fences that restrict access to machines.” When stock is fed into machines, operators should “safeguard by distance”—that is, “maintain a safe distance between their hands and the point of operation.”
Your people aren’t well-trained—or you can’t prove that they are: If you can’t certify that every employee who works with hazardous machines has received the proper training, you’re at significant risk of an accident or violation.
How to Avoid a Machine Guarding Violation: Your Prevention Checklist
1. Have you identified ALL machine-related injury risks? The first step in preventing injuries and ensuring compliance with OSHA’s machine guarding requirements is to identify every piece of equipment that could expose an employee to an injury. This may require a full walkthrough of your facility or facilities.
2. Do you have adequate guards in place on ALL machines? Keep in mind that not all machines have built-in safeguards, and that not all manufacturer-provided safeguards meet OSHA’s requirements. Sometimes, a skilled user may need to alter and improve the equipment or design and build new guards. Whether provided by the manufacturer or designed and built by the user, every guard must…
- meet the minimum OSHA requirements
- prevent workers’ hands, arms, and other body parts from making contact with dangerous moving parts
- be firmly secured and not easily removable
- ensure that no objects can fall into the moving parts
- permit safe, comfortable, and relatively easy operation of the machine
- allow for the machine to be oiled without removing the safeguard
3. Is there evidence that any safeguards have been tampered with or removed? If so, you’ll need to address the issue.
4. Are there guards in place for ALL hazardous parts of machines? Guards must be provided for any hazard at a machine’s point of operation. (Alternatively, where possible, you can alter the machine to eliminate point-of-operation hazards.) In addition to guards at the point of operation, guards should protect against other moving parts such as the following:
- gears, sprockets, pulleys, and flywheels
- exposed belts or chain drives
- exposed set screws, key ways, collars, etc.
Additionally, starting and stopping controls should be within easy reach of the operator. When there is more than one operator, separate controls should be provided.
5. Are you guarding against electrical hazards? Machines should be installed in accordance with National Fire Protection Association and National Electrical Code requirements. Conduit fittings should be secured, machines should properly grounded, and power supplies correctly fused and protected. Look out for injuries—even a minor shock can indicate a potentially life-threatening issue.
6. Are you providing extra protection when necessary? In some instances, if guards can’t eliminate every hazard, OSHA requires you to use “miscellaneous aids” to provide additional protection to workers. Examples include awareness barriers, which call attention to hazards, as well as specialized hand tools (e.g. push sticks and blocks) for feeding and/or removing stock.
7. Are you safeguarding workers against non-mechanical hazards? OSHA requires you to protect workers from noise hazards and harmful substances emitted or discharged from machines. These hazards can be controlled through special guards, enclosures, and personal protective equipment.
8. Can guards be removed safely? OSHA requires you to have a system in place for shutting down the machinery and locking/tagging out before safeguards are removed.
9. Have ALL operators undergone safeguarding training? OSHA requires any worker who uses hazardous machines to undergo specific and detailed training in the following:
- a description and identification of the hazards associated with particular machines
- the safeguards themselves, how they provide protection, and the hazards for which they are intended
- how to use the safeguards and why
- how and under what circumstances safeguards can be removed, and by whom (in most cases, repair or maintenance personnel only)
- when a lockout/tagout program is required
- what to do (e.g. contact the supervisor) if a safeguard is damaged, missing, or unable to provide adequate protection
Safety training is necessary whenever a new employee is hired to operate, maintain, or set up equipment; when any new or altered safeguards are put in service; and when a worker is assigned to a new machine or operation.
10. Are you continually monitoring your equipment and employees? Supervisors should frequently inspect equipment to ensure the guards are in good working order and functioning properly. These inspections should occur on a regular schedule and when the equipment is in use, so issues can be corrected immediately.
For more information and guidance about preventing an OSHA machine guarding violation, please contact us.