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Potential OSHA updates are poised to increase productivity

Keeping plant workers safe while maintaining production efficiency is paramount in food and beverage operations. But there’s a huge opportunity in the offing as OSHA prepares to revamp its lockout standards.

Bruce Main
Bruce Main, president of design safety engineering, inc. and machine safety consultant to PMMI, The Association for Packaging and Processing Technologies
Photo courtesy of design safety engineering, inc.

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.

Bruce Main, president of design safety engineering, inc. and machine safety consultant to PMMI, The Association for Packaging and Processing Technologies, has spent several decades helping companies improve the safety of their products, machinery and facilities. Main has been actively involved in ANSI and ISO standards development and has served in leadership roles with both organizations. In addition, Main has developed a variety of methods to help manufacturers reduce risk in areas such as design changes, guarding systems, warning labels, instructions and work procedures.

Earlier this year, OSHA conducted a request for information (RFI) to industry concerning the control of hazardous energy (lockout/tagout). In this interview with ProFood World, Main explores the current state of related OSHA requirements and potential standard updates.

ProFood World: 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 the energy sources will be isolated at energy-isolating devices, the machine will be shut down to clear the jam, and only then will power be restored. So, plant floor workers must follow full lockout.

PFW: Please describe the current OSHA standard. 

Main: ANSI Z244.1 is the industry standard for the control of hazardous energy. It was published in 2016. It has gone through several revisions since it was first published in 1982. It lays out the requirements to use alternative methods for controlling hazardous energy. And these alternative methods would be the systems that you rely on, other than lockout/tagout, to control hazardous energy.

tagoutsTagouts are used to control hazardous energy for multiple energy-isolation sources.Photo courtesy of design safety engineering, inc.

PFW: On the plant floor, what has changed over the past 40 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 the systems are designed correctly, we can rely on advanced control systems to control the 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 to allow the worker to open the gate, reach in, clear the jam, close the door, reset, restart, and get back into production.

PFW: What are the key concerns in this area?

Main: The key concern is how do we keep people safe from harm? That’s a fundamental element that is common to both OSHA as well as to machinery users. In the food and beverage industry, there’s a lot of concern about speed and keeping machines productive and operational. 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.

PFW: Can you provide an example where machine safety is not properly designed?

Main: A common one is an emergency stop, or e-stop circuit. Depending on the level of risks, the architecture of a control circuit, such as an e-stop circuit, may need redundancy in that system. And it’s not uncommon at all to have e-stop circuits that have a single channel. What that means is a single fault can result in a loss of a safety function. So, we know faults will occur. We know that with vibration, wires are going to become loose, welds are going to break, or wires are going to short and failures will occur. The question is what happens when those failures occur? How does it fail? Did the system fail to a safe state or an unsafe state? If you have a single channel, it is very likely that the failures can result in the loss of the safety function so that e-stop may not work when somebody really needs to use it. One of the huge questions about the use of control systems is how do you know what is good enough for the application?

PFW: What are the opportunities here for food and beverage manufacturers?

Main: The opportunities are quite large, especially if you have an application where you’re able to clear jams or perform tasks that require energy, such as jogging a machine, or performing setup 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 food and beverage producers to know that the systems they’re using on the machines that have alternative methods in place is considerable. If OSHA were to consider that use to be acceptable under its revised rules, food and beverage facilities can run safely with much greater efficiencies.

energy-isolation deviceAn energy-isolation device is used for lockout/tagout on a food and beverage line.Photo courtesy of design safety engineering, inc.

PFW: How can food and beverage processors determine if they can 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 lock out, 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 OK to reach into a machine to clear a jam relying on this alternative method, is it also OK to change a belt or change out a part? That depends on the risk assessment that has been done, and what tasks are considered as being allowed to be done under the alternative method. Scope creep refers to doing other tasks that need to be done, but 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. 

PFW: Please explain what has been happening recently with OSHA concerning the RFI 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 asking 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. 

PFW: Who responded to the questions, and what were some of the responses?

Main: Close to 90 substantive responses to the RFI were from a number of different industries and organizations, including PMMI.

Many industry responses pointed to the Z244.1 requirements under alternative methods as the means to effectively implement technology in an appropriate manner so that we keep people safe without negatively impacting productivity beyond what is currently required.

Some of the responses focused on the fact that OSHA is not alone in this effort and that OSHA should reach out as a team with industry to develop solutions. They should not try to do it all alone. 

The alternative methods to lockout should be allowed for machinery, equipment or processes where the tasks have been identified and risks reduced to an acceptable level that is documented in a risk assessment. 

Fundamentally, OSHA should realize that the system is the key, not just components or devices in isolation. 

Another type of response was that OSHA should focus on what to control, not how to control hazardous energy. So strict and prescriptive rules on how to control hazardous energy will fail to keep up to date with current industry trends.

Another kind of response looked down the road in the five- to 10-year range on vertical integration. If OSHA agrees that hazardous energy can be controlled in certain ways, those methods will be worked into new machinery, and users in the food and beverage industry will require those solutions be provided so they can take advantage of them. 

PFW: When do you think any changes will actually occur?

Main: I don’t anticipate any changes for over a year, and that’s 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. And no government agency wants to end up being a lightning rod during an election year. 

PFW: How are machine builders anticipating what’s going to happen and making changes to machinery?

Main: Even a year from now when OSHA comes with the next step, there are rulemaking procedures that it has to work through to revise the standard. These rules are rather cumbersome. It’ll probably take two to four years to actually get to a new rule if they go all the way through rulemaking. 

Machinery manufacturers can’t wait, and so they are starting to integrate methods using risk assessment and alternative methods to provide solutions. And the best ones are basing their solutions on the Z244.1 methodology to be able to demonstrate that they’ve achieved acceptable risk with their solutions. 

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