OEM guidelines for safety in new machines

HI,
I am currently working with a firm that is re-building old machines. While crunching numers, it appears money can be saved by starting all over with a new control cabinet. Replacing the old control relay logic, and contactors with as much that can be controled through a PLC. While management sees the cost benefit, I was informed that due to current saftety regulations, since we are rebuilding an old machine ( think 30-40 years ) we do not have to bring the machine to all of the current safety standards as we do a brand new machine. But The worries are at some point if enough things are replaced in the electrical part, that we could work our way out of the current niche of not having to re-qualify the machine to current manufacturing standards.

Does anyone have any experience with this and could dirrect me to a way to get clear answers?

Thanks

any machine must conform to the safety regulations even if rebuild, or anything like it. If you sell the machine you must give a conformation document.
Example: you are not allowed to operate a simple drill when not double insulated, and without proper safety measurements, like a goggle etc.

When you rebuild the machine, you need to adhere to current standards, not the standards that existed when the machine was first built. If the design of the machine makes it more expensive to comply, that becomes a factor in the choice between rebuilding and buying a new machine.

Picture yourself on the witness stand in a liability lawsuit. The defendant sits silently but with his mangled hand in plain sight of the jury. Try to explain that you didn't upgrade the machine to the same level of protection as a brand new machine because "due to the machine's age, we didn't have to".

Remember this. When an employee accepts a worker's compensation settlement, he gives up the right to sue his employer. He is, however, free to sue anyone other than his employer against whom he can make a claim for liability. That would certainly make your company fair game and don't expect your customer to participate in your defense.

I there is still a grey area, I mean new guards are installed were there were none, they are wired up to the controls so they cut control power when open. Audible alarms and light stacks are added.

For instance, if this were a car, and a '69 camaro was restored. I have to bring it back to perfect mechanical working order. Brakes have to work, tail lights... etc... But you wouldn't be required to install airbags and make the drive train adhere to current. And then re-engineer the the structure to meet current impact / collision guidelines...

The caveat is that you can only work on a pre existing machine, I can't split a machine, add in new parts and create two machines out of one old one.

There may be any number of gray areas, and the standards and regulations are subject to interpretation. Your goal as a rebuilder should be to make the machine functional and efficient without compromising operator safety.

The analogy to the older model car isn't appropriate in this case. When you restore an old car, you don't have to retrofit airbags, but you may have to live with restrictions on when, where, and how often you can operate that restored car on public roads. You'll also find your insurance premium on that restored vehicle is a lot higher than the premium for the car you drive to work every day.

Also on the subject of insurance. If you are sued over an injury on one of your retrofitted machines, your insurance carrier is obligated to defend you, but if there is a large judgement or settlement against you, they'll drop your coverage once the lawsuit is resolved. Finding a new carrier won't be fun and will cost a lot more. Your best defense against a liability suit starts before you ever get sued.

Who informed you that you don't have to meet current safety requirement?

Just the fact that you know the machine in inadequate as compared to current safety requirements suggests that you really should be upgrading the machine.

The comparison with a car is not the same, that is the risk you take with your life, not anyone elses. If GM was to rebuild a 69 Camaro and resell it, then it better meet all the current safety requirements.

Really, do you feel right about the fact that your company is willing to cut corners on safety to save a few dollars?

If you are refurbishing a machine then you must upgrade safeties to current standards. Refurbishing is not the same as repairing a machine. It is really not when a 3rd party (you) are involved.

I am surprised you haven't been socked yet. Generally most companies re-asset refurbished machines so they can get a larger tax break and in most areas that machine has to be inspected by OSHA again for safety.

The caveat is that you can only work on a pre existing machine, . . .

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Really you can do any thing you want to, including building a new machine, or rebuilding an old machine without adequate safety devices. The question as always is: is it smart to do that, and how long can you get away with it before going bankrupt?

Whenever we upgrade anything (we have a few machines still running on stuff from the 40's) we must upgrade the safeties to meet current standards. This does not include simple replacement of parts for other parts (like replacing one style of relay for an older style) but for true upgrades, safety is priority one. Always.

The cost of upgrading some of our oldest machines has pushed us toward buying new ones because retrofitting really old machines with new tech isn't as cost effective as simply installing a new one in its place.

Steve Bailey said:

When you rebuild the machine, you need to adhere to current standards, not the standards that existed when the machine was first built. If the design of the machine makes it more expensive to comply, that becomes a factor in the choice between rebuilding and buying a new machine.

Picture yourself on the witness stand in a liability lawsuit. The defendant sits silently but with his mangled hand in plain sight of the jury. Try to explain that you didn't upgrade the machine to the same level of protection as a brand new machine because "due to the machine's age, we didn't have to".

Remember this. When an employee accepts a worker's compensation settlement, he gives up the right to sue his employer. He is, however, free to sue anyone other than his employer against whom he can make a claim for liability. That would certainly make your company fair game and don't expect your customer to participate in your defense.

Click to expand...

+1 here.