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What are “Unbiased Risk Assessments”?

Unbiased Risk Assessments are guided by safety experts that have your best interests in mind.  Product companies, integrators, and solution providers may steer you toward expensive, overly-complex technical solutions.  Machine Safety Specialists provides unbiased Risk Assessments.  See examples below.

Biased risk assessments can happen when a safety products company, integrator, or solution provider participates in the risk assessment. The participant has a conflict of interest and may steer you towards overly expensive or complex solutions that they want to sell you.  Some safety product companies will do anything to get involved in the risk assessment, knowing they will “make up for it” by selling you overly expensive solutions.  Safety product companies have sales targets and you could be one of them.

Machine Safety Specialists are experts in OSHA, ANSI, NFPA, RIA and ISO/EN safety standards. We can solve your machine safety compliance issues, provide unbiased Risk Assessments, or help you develop your corporate Machine Safety and Risk Assessment program.

Case Study: Machine Safety Verification and Validation

A multi-national food processing company had a problem.  A recent amputation at a U.S. food processing plant generated negative publicity, earned another OSHA citation, and caused significant financial losses due to lost production.  Another amputation, if it occurred, would likely result in more lost production, an OSHA crackdown, and, if posted on social media, irreparable damage to the company’s brand.

After multiple injuries and OSHA citations, the company contacted MSS for help.  First, the company needed to know if the existing machine safeguarding systems provided “effective alternative protective measures” as required by OSHA.  MSS was contracted through the company’s legal counsel to audit three (3) plants with various type of machines and deliver detailed Machine Safety compliance reports for each machine to the client under Attorney Client Privilege.  A summary in our safeguarding audit reports for one plant was as follows:

For the 19 high risk and 8 medium risk (poorly guarded) machines, action by applying risk reduction measures through the use of the hierarchy of controls was required.  MSS provided a Machine Safeguarding specification for the machines and worked with our client to select qualified local fabricators and integrators that performed the work in an aggressive schedule.  MSS provided specifications and consulting services, and our client contracted the fabrication and integration contractors directly, under the guidance of MSS.

During the design phase of the Machine Safeguarding implementation, MSS provided safety verification services and detailed design reviews.  Due to the stringent legal requirements and the need for global compliance, the safety design verification included SISTEMA analysis of the functional safety systems.  MSS provided a detailed compliance report with written compliance statements covering OSHA compliance, hazardous energy controls (Lockout/Tagout, LOTO, OSHA 1910.147) and effective alternative protective methods, per OSHA’s minor servicing exception.  Due to the complexity of the machines and global safety requirements, MSS verified and validated the machine to numerous U.S. and international safety standards, including ANSI Z244.1, ANSI B11.19, ANSI B11.26, ISO 14120, ISO 13854, ISO 13855, ISO 13857 and ISO 13849.

Then, after installation and before placing the machines into production, MSS was contracted to perform safety validation services as required by the standards.  During the validation phase of the project, MSS traveled to site to inspect all machine safeguarding and validate the functional safety systems.  This safety validation included all aspects of the safety system, including barrier guards, interlocked barrier guards, light curtains, area scanners, the safety controllers and safety software, safety servo systems, variable frequency safety drives (safety VFDs), and pneumatic (air) systems.

After the machine safeguarding design verification, installation, and safety system validation, MSS was pleased to provide the following data in the executive summary of the report.

By involving Machine Safety Specialists (MSS) early in the project, we can ensure your project complies with OSHA, ANSI/RIA, NFPA and ISO safety standards.  By helping you implement the project, we kept the safety project on-track.  Our validation testing and detailed test reports provide peace of mind, and evidence of due diligence if OSHA pays you a visit.  Contact MSS for all of your Machine Safety Training, Safeguarding Verification, and on-site functional safety validation needs.

Case Study:  Collaborative Robot System

A global OEM needed to automate 30 existing manufacturing lines across 12 plants.  The OEM selected Collaborative Robot (“Cobot”) technology due to Cobots’ simplicity, flexibility, and presumed safe operation.  To implement the Collaborative Robot systems, they chose a custom machine builder that accelerated the schedule by taking exception to supposedly nebulous “safety standards”.   Six weeks later, the machine builder delivered a seemingly impressive Collaborative Robot assembly system to the plant.  Engineers quickly completed commissioning and the Collaborative Robot system went into production.  As the Collaborative Robot worked in close proximity to the plant associates, troubling questions weighed on the project team….

• Is this Collaborative Robot system safe?
• How can we validate the safety of the Collaborative Robot system before duplicating it?
• If we ship these globally, will we comply with global safety standards?
• What if the Collaborative Robot hurts someone?
• What about OSHA?

The OEM called Machine Safety Specialists (MSS) to solve these concerning problems.   Prepared to help, our TÜV certified Machine Safety engineers discussed the Collaborative Robot system, entered an NDA, and requested system drawings and technical information.  On-site, we inspected the Collaborative Robot, took measurements, gathered observations and findings, validated safety functions, and spoke with various plant personnel (maintenance, production, EHS, engineering, etc.).  As part of our investigation, we prepared a gap analysis of the machine relative to RIA TR R15.606, ISO 10218-2, OSHA, ANSI, and ISO standards.  The final report included Observations, Risk Assessments, and specific corrective actions needed to achieve US and global safety compliance.   Examples of our findings and corrective actions include:

• Identification of the correct safeguarding modes (according to RIA TR R15.606-2016 and ISO/TS 15066-2016).
• Observation that Area Scanners (laser scanners) provided by the machine builder were not required, given the Cobot’s modes of operation. Recommended removal of the area scanners, greatly simplifying the system.
• Observation that the safety settings for maximum force, given the surface area of the tooling, provided pressure that exceeds US and global safety requirements. Recommended a minimum surface area for the tooling and provided calculations to the client’s engineers.
• Observation that the safety settings for maximum speed were blank (not set) and provided necessary safety formulas and calculations to the client’s engineers.
• Recommended clear delineation of the collaborative workspace with yellow/black marking tape around the perimeter.

With corrective actions complete, we re-inspected the machine and confirmed all safety settings.  MSS provided a Declaration of Conformance to all applicable US and global safety standards.  The customer then duplicated the machines and successfully installed the systems at 12 plants globally, knowing the machines were safe and that global compliance was achieved.   Another success story by MSS…

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Case Study:  Robot Manufacturing

A US manufacturer was attempting to automate a complex task – assembly of an elastic sheet in a complex frame, then cutting it precisely.  This process required 16 people across four US plants, and the manual process simply could not keep up with orders.  In addition, due to employee fatigue, quality issues were frequent and senior management demanded a solution.   The project team’s first challenge?  How to develop a custom robot cell and deliver it in a tight schedule.

The manufacturer hired a robotics integrator and a brief engineering study determined that speed and force requirements required a high-performance Industrial Robot (not a Cobot).  The client issued a PO to the integrator, attached a manufacturing specification, and generically required the system to meet “OSHA Standards”.  Within 3 months, the robot integrator had the prototype system working beautifully in their shop and was requesting final acceptance of the system.   This is when the second problem hit – the US manufacturer experienced a serious robot-related injury.

In the process of handling the injury and related legal matters, the manufacturer learned that generic “OSHA Standards” were not sufficient for robotic systems.  To prevent fines and damages in excess of $250,000, our client needed to make their existing industrial robots safe, while also correcting any new systems in development.   The manufacturer then turned to Machine Safety Specialists (MSS) for help.

Prepared to help, our TÜV certified and experienced robot safety engineers discussed the Industrial Robot application with the client.  MSS entered an NDA and a formal agreement with the client and the client’s attorney.  On-site, MSS inspected the Industrial Robot system, took measurements, gathered observations and findings, tested (validated) safety functions, and met with the client’s robotics engineer to complete a compliance checklist.   As part of our investigation, we prepared a Risk Assessment in compliance with ANSI/RIA standards, an RIA compliance matrix, and performed a gap analysis of the industrial robot systems relative to ANSI/RIA standards.  The final report included a formal Risk Assessment, a compliance matrix, our observations, and specific corrective actions needed to achieve safety compliance.

Examples of our findings and corrective actions included:

• A formal Risk Assessment was required in compliance with ANSI/RIA standards (this was completed by MSS and the client as part of the scope of work).
• Critical interlock circuity needed upgrading to Category 3, PL d, as defined by ISO-13849. (MSS provided specific mark-ups to the electrical drawings and worked with the integrator to ensure proper implementation).
• The light curtain reset button was required to be relocated. (MSS provided specific placement guidance.)
• The safeguarding reset button was required to be accompanied by specific administrative. (MSS worked with the integrator to implement these into the HMI system and documentation).
• The robot required safety soft limits to be properly configured and tested (Fanuc: DCS, ABB: SafeMove2).
• Specific content needed to be added to the “Information for Use” (operation and maintenance manuals).

With corrective actions complete, MSS re-inspected the machine, verified safety wiring, validated the safety functions and provided a Declaration of Conformance for the robot system. The customer then accepted the system, commissioned, and placed it into production.  The project was then deemed a huge success by senior management.   The industrial robot system now produces high-quality assemblies 24/7, the project team feels great about safety compliance, and the attorneys are now seeking other opportunities.   Another success story by MSS…

Case Study: Manufacturing Company

Background: A safety products company was contracted to perform a risk assessment. Result: The most expensive products and solutions were recommended by the product company. The client purchased and installed the materials, resulting in an improper application of a safety device. The hazard was not effectively abated. The Employer’s liability existed until MSS identified the problem, the light curtain was replaced, and the system was validated. Machine Safety Specialists specified the correct light curtain and a compliant, cost-effective solution was finally installed. This really happened  – Don’t let it happen to you !

Another question….

Q:  Which safety product company do we trust to perform a risk assessment with your best interest in mind? A:  None of them. Companies selling safety products have a hidden agenda – sell the most products and charge insane dollars for installation! Machine Safety Specialists are safety engineers and consultants who have your best interest in mind. We will conduct an unbiased Risk Assessment and recommend the most sensible, lowest cost, compliant safeguards on the market – with no hidden sales agenda!

Case Study: Machine Safeguarding Example

One Photo, Two Points of View….

Safety Product Company Recommendation:

“Wow – This Customer needs $50K of functional safety equipment on each machine. Add light curtains, safety system, software, etc….”.  Problem solved for $50,000.

MSS Recommendation:

“Bolt down the existing guard, add end cap, remove sharp edges and secure the air line. Add a warning sign with documented training….”.  Problem solved for $50.   Once again, this really happened  – don’t let it happen to you !

Case Study: Risk Reduction

“Machine Safety Specialists’ comprehensive approach to risk reduction ensured the most complete, sensible, and least expensive solution for compliance” – Safety Manager

Green Circle (right): We use all methods of Risk Reduction (elimination, signs, training) – not just guards and protective devices. This is the least expensive and most comprehensive approach. Red Circle (right): Guarding company methods of risk reduction (guards and protective devices) are very expensive, time consuming, and do not mitigate all of the risk.

Case Study:  Applicable U.S. Machine Safety Codes and Standards

We are often asked: “What must I do for minimum OSHA compliance at our plant?  Do I have to follow ANSI standards?  Why?” The following information explains our answer… Please note the following excerpt from an actual OSHA citation:

 “These machines must be designed and maintained to meet or exceed the requirements of the applicable industry consensus standards.  In such situations, OSHA, may apply standards published by the American National Standards Institute (ANSI), such as standards contained in ANSI/NFPA 79, Electrical Standard for Industrial Machinery, to cover hazards that are not covered by specific OSHA standards.”

 U.S. regulations and standards used in our assessments include:

• OSHA 29 CFR 1910, Subpart O
• ANSI B11.0
• ANSI Z244.1
• ANSI B11.19
• ANSI B155.1
• ANSI / RIA R15.06
• NFPA 79
• Plus, others as applicable….

Please note the following key concepts in the U.S. Safety Standards:

• Control Reliability as defined in ANSI B11.19 and RIA 15.06
• Risk assessment methods in ANSI B11.0, RIA 15.06, and ANSI/ASSE Z244.1
• E-Stop function and circuits as defined in NFPA 79 and ANSI B11.19
• OSHA general safety regulations as defined in OSHA 29 CFR 1910 Subpart O – Section 212
• Power transmission, pinch and nip points as defined in OSHA 29 CFR 1910 Subpart O -Section 219
• Electrical Safety as defined in NFPA 79 and ANSI B11.19.

Note:  OSHA is now citing for failure to meet ANSI B11.19 and NFPA 79.