OSHA Safety Req'ts with machine Retrofits

People, I am wondering if anyone has had any experience with the "safety" systems used in today's machinery.

I work in a production facility in which an employee was injured due to machine-design problem. (the machine is over 15 years old)

Not to mention all of the details, but I am curious as to the process that is REALLY required when dealing with a machine that needs to be updated in order to meet today's safety standards.

For example, the machine does not incorporate an AIR DUMP solenoid or any E-STOP Safety-type relay in the system after the machine guarding is defeated. It is using a STD MCR to seal in the outputs, but does not allow for secure methods of restraining cylinders and heaters..etc.

We have a safety department, but they really don't know everything...... in my opinion.

What are the real requirements for rectifying the situation? Does a Safety Relay need to be added, along with mechanical protection (to restrain falling cylinders.etc) I seem to recall reading that if there was ever any upgrades to a control system, that the new process needed to meet the minimum safety sytems protection guidelines. (Most machines that are shipped are incorporating double-safety contact relays and components.)

BTW, this is NOT A PRESS.

Hello SNK;

the process to analyse injury potential and solutions is called Risk Assesment. Most health and safety boards implement some form of charts and training materials (in Quebec it is done by the IRSST)using standards based on OSHA, EN 954-1, and others. This is not an amateur league subject, as human lives and livelyhoods are at stake.

The determination of such and such a safety relay or element to reduce hazards must be analized in a context or risk protection level requirements.

I will attach a few very general pdf documents that gives a very small perspective on requirements and possible solutions depending on safety level requirements. I hope others can join in this thread and bring their experience on the subject.

Hope this helps,
Daniel Chartier

Good Information.
Let's keep this thread running.

SNK,

Your first step is to do a preliminary Risk Assessment using the guidelines in the documents that dchartier kindly provided. Figure out all the possible ways the machine can be unsafe, and also the severity, frequency, and avoidance for each way. Anything you can eliminate with hard-guarding, do so, as that will greatly decrease the complexity of the safety system.

Once you've identified where you need something more complex, such as safety light curtains or interlocks, find a couple good integrators who have experience in safety. Certainly you could do this on your own, but it's good to have experience on your side. This also depends on severity. If the danger is a pinched finger, go at it. Where lives are at stake, find the best quality integrator possible!

SICK, Inc. (machine safety supplier) recently signed on Rockford Systems, Inc. as a business partner specifically for safety system integration. That may be a good place to start, but try to find someone local, as that will mean better support.

Other machine safety suppliers include Banner, STI, and the ubiquitous AB. I know more about SICK, though, since my company distributes for them them.

The last place I worked wanted to upgrade a web handling machine. These upgrades were limited to larger rollers and an updated dancer system for the main unwind. We went to the OEM for these changes.

The OEM told us that we had to bring the old machine up to present day safety requirements and gave us a bid for those upgrades, as well. The safety additions included some safety mats and pull cords, as well as a rendundant e-stop circuit.

They told us that this was a requirement. And if we didn't want to install the safety stuff, that we had to sign a waiver indicating that it was our decision not to do it--to cover their a$$.

So I think that its a rule that if you make any upgrades to machinery, safety items must be considered, whether safety is the reason for the idea to upgrade, or not.

john paley said:

The OEM told us that we had to bring the old machine up to present day safety requirements and gave us a bid for those upgrades, as well. The safety additions included some safety mats and pull cords, as well as a rendundant e-stop circuit.

They told us that this was a requirement. And if we didn't want to install the safety stuff, that we had to sign a waiver indicating that it was our decision not to do it--to cover their a$$.

Click to expand...

Thanks for the replies guys. This is the type of information that I am looking for. The machine pinched a finger as a Cylinder Fell in the downwards position, after the door was opened. As mentioned earlier, there was no Dump solenoid in the control circuit, but there is a MCR that gets sealed in electrically with all of the safeties (E-STOP switches and door contacts).

My REAL QUESTION I think is answered, but I need someone to CLARIFY FACTS of where to find this information. Because I will be adding a DUMP SOLENOID to the MCR circuit, do I now have to install a Safety Relay in place of the MCR? My point is if ANY UPGRADE is to be made, do we have to bring the whole machine up to current code?

OSHA standards are available online: www.osha.gov

Another good source is: www.sti.com

I did not get what the machine was but it appears that it may be some kind of press, if so then you will probably need to use safety relays and other safety related control products.

SNK said:

We have a safety department, but they really don't know everything...... in my opinion.

Click to expand...

Sometimes, the safety department doesn't know ANYTHING...

Seriously, you can read all the OSHA stuff you want. The bottom line is almost all machinery is "special" in some way. Consequently, nearly every facet of safety is up for interpretation of some standard, OSHA or otherwise. Your company needs to have a system in place that the appropriate parties "buy off" your design.

I would never design (and especially implement and put in operation) anything until I had the blessings of EVERYBODY. This includes: management, production, safety, engineering, etc.

I am being ask to replace several old automate 31 and 32 control systems with new RS Logix 5000 systems, all of this equipment is 30 plus years old. The machines vary from paper rewinders to wood chip reclaimers. My question is at what point is it required that the machines be updated to present safety standards??

welcome to the site
Please post these as a new post this is 6 years old

However ugrading machinery control - DOES - require the upgrade of the safety controls to the new standards
Even if the company name changes.
This is to bring machinery up to date.
This may be different in the U.S. but I doubt it.

Thank you Ian Trost , it seems I will need to upgrade my management team. This will help.

You're upgrading/modernizing controls on a machine that is 30+ years old. Why would anyone try to get away with obsolete practices instead of upgrading to current standards? If you don't apply current best practice and anyone were to get injured on any of the refurbished machinery, be assured that OSHA will be asking questions for which you don't have good answers.

There may not be a clear cut dividing line between when you can continue to operate under older standards and when you must comply with current standards, but it's a pretty good bet that replacement of an obsolete PLC with a new platform falls into the category where you'll need to comply with current standards.

Steve, you are 100% correct, I don't have the answers to these questions, but I have read/researched/googled enough to know that my employer is asking us to do things that we don't think is right because of their lack of understanding that we can't do things like we did 25-30 years ago. My goal is to have enough responses/inputs from this forum that I can print out and show Production Managers, Maintenance Managers and Engineering that my concerns have merit. I have sent a query on line to OSHA, buy have not received anything back from them yet to show to my managers. There is a PLC upgrade on one of our large Rewinders scheduled for April 30th on a three day outage, without any of my concerns being addressed. My hope is to have this re-scheduled until these issues are resolved....

we have written standards here that demand the update of safety to machines if the machine owner changes or the company changes or the addrress changes
and
ofcourse if the control system is changed in any way.
This does include any Pneumatics and Hydraulics.

markabuskirk said:

My question is at what point is it required that the machines be updated to present safety standards??

Click to expand...

I often see safety questions phrased like this: what must I do to meet OSHA or some other requirement. If someone gets injured at the plant, litigation and liability won't stop simply cause you hit some magic OSHA minimum. In most cases, any settlement will be a couple of orders of magnitude more than any fine from OSHA. Safety is about removing unacceptable risk.

Functional safety has moved forward remarkably in the last 30 years. Have your bosses consider the cars they carry their children in. Do they rely on 30 year old safety technology to protect their own kids? No air bags, no anti-lock braking, no other safety advancement since the 70's.