Automation Canada Machine Safety Issue May 2021 - 19

MACHINE SAFETY: IS IT ON OR OFF?
With the increased demand on our industrial workforce, many facilities are expanding the " do more with less " approach when it comes to machine
Following the five steps of the machine
safety lifecycle helps mitigate risk
safety. Today, environmental, health and safety (EHS) and similar professionals are more likely to have their responsibilities expanded beyond
programs such as Lockout/Tagout (LOTO) and Confined Space. They may now be expected to design and test functional safety devices such as light
curtains, area scanners and guard gates that historically were the responsibility of the plant engineer or equipment manufacturer.
Although these safety controls can be a vital part of machine interaction and safety that can enable minor servicing tasks to be completed without
lockout of the machine, there is still confusion on the application of LOTO and alternative protective measures (APM). When do we use LOTO and
when do we use APMs?
OSHA's Control of Hazardous Energy regulation (1910.147) allows for alternative methodologies to be used so long as they are " as effective as
lockout/tagout " for the task. And that's where many companies run into problems. Oſten we see cases of companies using the exception clause to
allow the employee to " create their own " path to safety if lockout/tagout is impractical. But this alternative method to lockout should not increase risk
to employees.
Following the five steps of the machine safety lifecycle as outlined will help you mitigate risk associated with potential hazards and document the
process.
1
2
Risk Assessment
A clearly defined risk assessment process serves as an effective tool for properly identifying and assessing the real hazards that are involved with
interacting with a particular machine. It provides a method for determining equivalent levels of protection when designing safeguards that allow the
safe use of OSHA's minor servicing exception.
The risk assessment process takes away the guesswork when estimating risk and prescribing safety system performance. The risk assessment is an
active, documented process that can be filed and maintained for the entire life of the machine and serves as documented proof of " due diligence. "
The risk assessment establishes the foundation and early framework for the design and implementation of an effective machine safety program.
Safety Functional Requirements Specification (SFRS)
The purpose for developing the safety functional requirements specification is to review the initial risk reduction recommendations from the risk
assessment and confirm the ability to implement them as recommended. The specification contains existing and proposed safety functions and will
serve as a basis for both the safety system design and the validation plan.
CANADIAN AUTOMATION
VOLUME 3, ISSUE 3
19

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Automation Canada Machine Safety Issue May 2021

Table of Contents for the Digital Edition of Automation Canada Machine Safety Issue May 2021