Customers are concerned about worker safety while maintaining production efficiency. But there’s a huge opportunity for machinery manufacturers as OSHA prepares to revamp its lockout standards.
Eliminating a potential safety problem before it happens is just common sense. But as plant floor technologies and automation become more advanced, there are opportunities to simultaneously enhance safety and production efficiency.
Earlier this year, the Occupational Safety and Health Administration (OSHA) conducted a request for information (RFI) to industry concerning the control of hazardous energy (lockout/tagout). Bruce Main, president of design safety engineering and safety consultant for PMMI, The Association for Packaging and Processing Technologies, explores the current state of related OSHA requirements and potential standard updates.
What are the current OSHA requirements for tasks such as clearing a jam?
Main: Under the strict requirements of OSHA, clearing a jam is considered to be a service and maintenance activity. Therefore, OSHA expects that the machine will be locked out, that an energy isolating device will isolate the energy sources and the machine will be shut down to clear the jam before restoring power. So, plant floor workers must follow full lockout.
When were the current OSHA requirements written?
Main: They were published in 1989 and were largely based on ANSI standard Z244.1. These requirements are more than 30 years old as ANSI standard Z244.1 was written in the mid-1970s and published in 1982.
On the plant floor, what has changed over the past 30 years concerning worker safety?
Main: Quite a bit, certainly with technology. New technologies enable the control of hazardous energy to be performed, rather than lockout. If designed correctly, we can rely on advanced control systems to control hazardous energy.
When clearing a jam, you can rely on the control systems such as an interlocked access gate that runs through an appropriate control circuit to control the energy and prevent an unexpected startup. This system allows the worker to open the gate, reach in, clear the jam, close the door, reset, restart and get back into production.
What are the key concerns in this area?
Main: The key concern is keeping people safe from harm. A second concern is how do we make sure people are kept safe, but also maintain production in a way that is safe but efficient. And that’s where there’s a huge opportunity to use alternative methods to improve systems that are as safe or safer than for lockout.
What are the opportunities here for CPG customers?
Main: The opportunities are quite large, especially if customers have an application where they are able to clear jams or perform tasks that require energy such as jogging a machine or performing set up changes under alternative methods that would not require locking out the machine. That means uptime on the machine can be dramatically improved. And the confidence of the CPGs to know that the systems they’re using on the machines that have alternative methods in place is considerable. If OSHA was to consider that use to be acceptable under its revised rules, facilities could run safely with much greater efficiencies.
How can machinery manufacturers determine if they can use alternate methods to improve uptime?
Main: They access and purchase the ANSI Z244.1 standard from the online ANSI store. Under that standard, lockout and tagout are the preferred methods to control hazardous energy. What that means is if we can lockout, we should. But if there are circumstances where alternative methods can provide better solutions, then the standard describes how to do it. That is a great place to start because one of the concerns is scope creep.
If it’s okay to reach into a machine to clear a jam relying on this alternative method, is it also okay to change a belt or change out a part? Main: That depends on the completed risk assessment, and what tasks are considered as being allowed to be done under the alternative method. Scope creep refers to doing other necessary tasks, which are not allowed as part of the original assessment. Only tasks that have been evaluated in the risk assessment using the alternative method should be done.
Please explain what has been happening recently with OSHA concerning the request for information to industry?
Main: OSHA has had the 1910.147 standard on its regulatory agenda for a while now. In May 2019, OSHA issued an RFI to industry. It asked for information on how the Agency might revise its requirements. OSHA submitted questions that were quite lengthy and diverse in terms of details on how to actually use these standards and the economic impact of alternative methods or lockout requirements. The questions focused on the safety impacts and the production impacts of requiring lockout as it currently is, as well as questions related to the economic impacts.
Who responded to the questions, and what were some of the responses?
Main: OSHA received close to 90 substantive responses to the RFI by August. A number of different industries and organizations responded, including PMMI. Many of the industry responses pointed to the Z244.1 requirement under alternative methods as the means to effectively implement technology appropriately so that we keep people safe from harm without negatively impacting productivity beyond what is currently required.
The alternative methods to lockout should be allowed for machinery, equipment or processes where a documented risk assessment identifies the tasks and reduces risk to an acceptable level.
Going forward, rather than writing prescriptive standards on how to control hazardous energy, it was a very common response to suggest to OSHA that the Agency should focus on what should be done. Another kind of response looked down the road in the five- to ten-year range on vertical integration. If OSHA agrees on certain ways to control hazardous energy, new machinery will incorporate those methods, and users in the food and beverage industry will require those solutions be provided so they can take advantage of them.
When do you think any changes will actually come about?
Main: I don't anticipate any changes for over a year, in large part because of the election in 2020. I think OSHA has an awful lot of homework to do with the information they received on the RFI, and they need to do independent analyses. No government agency wants to end up being a lightning rod during an election year.
What can machinery manufacturers do now?
Main: Machinery manufacturers can’t wait and should start to integrate methods using risk assessment and alternative methods to provide solutions. It is best to base solutions on the Z244.1 methodology to be able to demonstrate that achieving acceptable risk is attainable with these solutions.