By Ellen Fussell Policastro
Within the industrial machine safety realm, standards developers have come up with a slew of documents to help manufacturers develop methodologies to determine hazards.
Unfortunately, operators can take shortcuts to undermine this process and pay a hefty price — injuries. The key to making this process work is to understand how operators work with equipment to identify hazards, understand the equipment as well as how different shifts operate it to analyze tasks, and document everything to ensure you are in compliance and your team is safe.
With 35 years experience working with plant safety, equipment risk assessments, and safety programs and procedures, Scott Krumwiede, a manager at GP Strategies in Detroit, knows risk assessment. Krumwiede gave the why, what, and how of completing a risk assessment for safe machinery in Wednesday’s Siemens-sponsored webinar, “Conducting a Risk Assessment: What You Need to Know.”
Krumwiede covered every aspect of risk assessment, from understanding the process and creating templates to looking at practical implementation and understanding documentation requirements.
Defining a Risk Assessment
A risk assessment is a process to recognize hazards, remove them, or reduce them to a tolerable level. You should complete your risk assessment over the first three stages of equipment life.
The first stage occurs in design.
“The cheapest time to take care of an obvious hazard in a piece of equipment is in the design phase because then you don’t have to add equipment or controls,” Krumwiede said. “You just design it out.”
The second stage occurs in build and runoff.
“When I have a piece of equipment on the floor already built, and I’m running it off, this is a time to actually see the machine working. Things we might not be able to see in the design and running stage, we might see in build and runoff,” he said. “We might find areas of danger we didn’t see in the drawing.”
The third and final stage occurs once the piece of equipment is sitting at a user’s site — in production.
Although you should be doing risk assessments when you design or develop a piece of equipment, unfortunately the assessment actually takes place in stage 3 — when equipment is in production.
Some reasons for this could be manufacturers don’t have time in the design stage, or build and runoff is always rushed. “I’ve found I get called in after equipment has arrived and is in production, then somebody gets hurt, or they want to review for hazards,” Krumwiede said. “So when it’s in production, and you do identify hazards, you have to rework to protect employees around it.”
Once your equipment is in production, revise risk assessment points yearly or when you make a change in the process that involves that piece of equipment.
“You should look at points involving the rest of the equipment life,” he said. “If you haven’t made any changes in a year, it will be a short review. But if you have, you may have created hazards, so they have to be identified and mitigated again.”
How to Identify Hazards
The automation industry defines a hazard as something that places someone at risk or in harm’s way. It can cause a slight injury, which is reversible and curable. And it can cause a serious injury, such as dismemberment and amputation. It can also cause death.
Who’s qualified to do a risk assessment? “Having a good solid understanding of mechanics and electrical is a great start,” Krumwiede said. “If you’ve been around a lot of different equipment, you’ve had a chance to learn how it all works.”
The first thing to do in identifying hazards is a test-based analysis of a piece of equipment. “Once it’s in production, I like to come in and see how the people running the equipment interface with it,” he said. “There have always been two ways a piece of manufacturing equipment operates: 1. The way we think it should be because we understand how they designed it and 2. The way the production staff learns to run it. But it could offer some hazardous opportunities while they’re running it. The designer may not have thought of it being operated that way. But the production staff will operate it the fastest and easiest away. They will learn every nook and cranny.”
Unfortunately, when the production on one shift learns the best way to do something, sometimes they don’t pass that knowledge on through best practices to other shifts. “Say we’re a two-shift operation,” Krumwiede said. “I’ll end up with two groups of operators running the equipment two different ways. That could present a dangerous situation.”
One shift may be running it safely and another taking shortcuts. “If the safety device we put in place impedes their cycle time or workflow, they aren’t going to just work with it. They’ll figure out a way to bypass safety so they can get back to what they were doing. When we identify mitigation steps to correct hazards and protect people, we need to make sure those steps do not interfere with the operators’ daily events. If so, they’ll work around it.”
When doing a task analysis, just go watch the machine — learn it and get to understand it. Depending on who is working on it and what they are doing, it will react differently. “When I identify all these different hazards, I want to make sure I can mitigate with everyone, not just for certain groups,” Krumwiede said.
So it’s important to understand the machine mechanically and electronically. Observe the people running it. How do they interface with it? “You’ll see people doing a lot of different things with the machine. Each person has his own task for operating that machine. We need to find out those tasks. Interview those people,” he said. “Some plants have one piece of production equipment with many stations to it — many people interfacing with equipment. And they rotate those positions throughout the day. So everybody learns everybody else’s task. You may find people who operate the same station do the job differently than others who work beside them on the same piece of equipment.”
You need to share best practices even on the same shifts. If one of those people knows how to run the station better, they should share that knowledge. Once you’ve understood all the equipment, document all the tasks for each person.
Some of the tools Krumwiede uses come from different standards throughout the industry. He’s collected that information and formed a spreadsheet.
“When you do a risk assessment for the first time, take a small piece of equipment — a standalone island small enough to put your arms around it so you can relate to it,” he said. Do your study of how it operates. Study the tasks. Then look at the equipment to see what kind of hazards just the equipment alone offers. Using these standards, you’ll be able to develop your own templates if you’re doing these risk assessments internally.”
Three areas for the template include: Data-gathering, a worksheet for tasks (write down what they do and any issues you see), and final output sheets with your input. (This is where you rank and rate individual hazards you’ve identified).
When you start your task assessment, list each task as independent from any of the others. “When I’m doing a task assessment involving three different hazards, I have to apply it singularly to each hazard,” he said. “That means if I’m interfacing with a robot station and adding a part to tooling, I may be exposed to three different types of hazards. I would list that issue this way: ‘Adding the part, I have this hazard, adding the part, I have that hazard,’ and so on, so you address each of those hazards on their own merit. We want to make sure we address each hazard and mitigate it to a tolerable level.”
Compliance with Regulations Crucial
There’s a general duty clause in OSHA’s Occupational Health Act of 1970 to help ensure employees are free from recognized hazards. Employers and employees have to comply with that. This is important because OSHA’s regulations are applicable for all kinds of different scenarios. “When an inspector can’t find something in the OSHA regulations that applies specifically to your issue, he can go to any one of the standards — ANSI, NFPA, NEMA, or ISO — to apply the general duty clause to your situation,” Krumwiede said. “And when they do that for your specific incident, that standard is now part of a violation you have to take care of. Under this clause, OSHA can literally bring in any other standard out there. So it makes sense for everyone to have an aggressive effort to avoid injuries and an aggressive policy for analysis and risk mitigation.”
Severity, Frequency, Avoidance
When you conduct a risk assessment, you have to determine levels of severity, frequency, and avoidance. In all three of these, experience is a necessity. In some cases it can be somewhat of a judgment call. Using the list of tasks associated with equipment, the assessor must determine if the task places an individual at any risk. If they discover risk, is it tolerable?
To determine severity, you will probably want to use a third party. “Large facilities can find this too time-consuming, and smaller facilities might not have the staff to conduct a risk assessment,” he said. “You also have to understand the latest standards, and of course, equipment experience needs to be there.”
Determining frequency boils down to how often the individual ends up exposed to hazards. Look at shift practices; first shift could think one way and second shift another. So, the second shift could be exposed more frequently to hazards.
And determining avoidance simply means you ask, “Can I avoid the hazard?” Remember shift-to-shift best practices. If they don’t do it the same way on each shift, there could be additional risks.
Learning Standards for Risk Assessment
Beginning to document the process is as important as the assessment itself. You need to document everything you see and put it on file. Some people think of everything on file as a liability, but it isn’t. It does mean, however, if you don’t have a risk assessment, you were not proactive in making your equipment safer. “The risk assessment is actually documented proof you took that step,” he said. “And the document can actually become a defense tool for you.”
One of the documents involved in risk assessments is the ANSI/ISO 12100:2012 revision. It goes through risk assessment and risk reduction, safety of machinery, and general principles of design. “If you pick up this document, you’ll be picking up a lot of other standards it references.”
ANSI/RIA R1506-1999 will give you tables and templates. “The 1999 version allowed me to set a design strategy in a risk reduction category. The R1–R4 areas tell me what kind of a circuit I need to build for that area of hazard,” he said.
EN954-1, the standard replaced by ISO13849, “also gave us a methodology in determining a kind of circuit for that protection level,” he said. “I still use the 1999 templates because they give me these levels. I can take these levels and associate them with ISO13849-1 and -2 2006, which I do in my risk assessments.”
Finally, when doing a risk assessment, you really have to do two. The before assessment is with no safeguarding; the after assessment is with safeguarding. Your first look at equipment is based on no guarding at all. Even if you have guarding, in your mind, take it away. So you identify each and every hazard. If there’s a spinning wheel and no possibility anyone can get to it, that’s fine. But you’d list that as a hazard. You’d mitigate the second half with your strategy being fix the guard, which would take your exposure and avoidance way down. You attack through exposure and avoidance.
Review equipment for operation, document tasks, identify hazards, and set performance levels. Construct your safety circuits with required performance-level components and determine your mitigation. Having mitigation in place, review and reassess; that’s your second assessment. Then validate all your logic for proper design function, and make sure it operates to the proper performance level needed.
Ellen Fussell Policastro is a freelance writer in Raleigh, NC. Her email is firstname.lastname@example.org.