Machine safety issues keeping you up at night?
Sounds like a case of the “Gray Space.”
David W. Kerr, E.H.S Consultant, MPSA
May 15, 2018
With downsizing efforts impacting every industry, the availability of in-house expertise of machine safety has declined. Still, you bear the responsibilty to provide a safe and compliant work environment to employees. The stakes are high, and machine-related injuries or audit findings are always in the back of your mind. You know your machinery needs to become safe and compliant, but you’re just not sure how to get there.
Injuries, audits, complaints, oh my! These are enough to keep any EHS professional up at night.
If this sounds familiar, don’t worry – you aren’t alone. The stress and obstacles can overwhelm any EHS professional (or anyone assigned to manage a machine-safety upgrade project). At MPSA, we call this the “Gray Space” of the project. It’s not a fun place to be, and only gets worse when internal stakeholders pressure you with a deluge of questions and concerns about potential machine changes. Below are a few examples – if you are currently in the Gray Space, a few excerpts may sound all too familiar:
“We had a very serious machine-related injury. We need to do something about this now – It could have easily been a fatality!”
“The equipment manufacturer refuses to modify the machine. They say we need to replace it!”
“Safety changes aren’t necessary. They’ll only reduce production and increase my cycle times!”
“We had a third-party risk assessment that identified several risks, but they didn’t say how to fix them. You’re on your own here.”
“We can’t leave the machine like this. If we have a regulatory inspection or audit, there will definitely be a violation.”
“For all we know, safety upgrades will cost more than the machine is worth.”
“The OSHA, ANSI, ISO, and NFPA safety standards are so confusing.”
“Safety changes will only restrict our access. Maintenance and repair will be impossible.”
“You bought those safety components? They’re not control reliable! The safety control design has to be ISO compliant.”
“We need to make sure machine changes have revalidation and Management of Change (MOC) documentation.”
While in the Gray Space, everyone has an opinion due to the number of impacted stakeholders who have valid concerns about how upgrades may impact their work or responsibilities. More often than not, nobody has the full authority or knowledge to resolve all of the comments or concerns. Thus, the Gray Space has the potential to stagnate any real solutions. All the while, employees remain at risk to serious injuries due to unresolved hazards.
If your safety upgrade needs are for common workshop equipment (e.g., lathes, drill presses, bench grinders, CNC machines, or cut-off saws), then you have an easier path in front of you. There are several “off-the-shelf” commercial solutions to choose from. State and federal OSHA regulations and industry consensus standards provide ample guidance on guard design, required dimensions and performance specifications for most workshop machinery.
However, if your machine safety upgrade needs are for high-speed, highly automated or robotic equipment, or an assembly of multiple machines, then the complexity and cost of machine safety upgrades are much more complex. This is when many employers reach out to an external machine safety partner for assistance. They can help navigate this complex and often lengthy process that may take months, if not years to complete. There are some proven approaches to implementing successful machine-safety upgrade projects, and several of these approaches follow a management-system framework that should be familiar to many manufacturing and EHS professionals. Overall, when an internal safety project takes a dive into the Gray Space, and external source of expertise and real-world solutions is the best way to get out.
With internal safety projects, there always seems to be a deluge of problems and no clear-cut solutions. Without an in-house safety expert, the best way to get actual safety solutions is through an outside safety partner. They can address your stakeholder’s questions and concerns and “take the wheel” during the safety journey. For tips on how to select your safety partner, we suggest reading: Never hire a machine safety company without asking these 10 questions.
About the Author
David W. Kerr has over 35 years of global EHS experience and retired as Director of Global Safety & Loss Prevention for Merck & Co., Inc. As MPSA’s EHS Program Specialist, Dave assists the MPSA Team and its clients with machine safety programs, compliance and training needs.
“Helping others to comply with EHS regulations & preventing serious, if not fatal injuries has been my life’s work.”
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