Machine Safety and Guarding: What Does it Mean to Have a Good Plan?
(Published in ASA News March 2011)
Every company wants to have a comprehensive and effective safety program; one that fosters employee safety and complies with all the relevant industry standards. What is most important to realize in any safety policy is that it is only as strong as its constituent parts. If one element of the policy is substandard, it demonstrates weakness in the framework and an unnecessary vulnerability to a negative event. While all plans within the safety policy are important, it is the Machine / Equipment Safety and Guarding Plan that many safety coordinators will point to as an area where injuries, if incurred, are routinely severe. A bad incident with a chop saw or wire spooling equipment rarely ends well. It is for this reason that management tends to pay extra attention to this area of the policy.
So what constitutes a good plan for machine / equipment safety and guarding? What things should it include? I will tell you that there are ten components for designing a plan on machines and equipment. Each component serves a specific function to ensure that the plan is consistent, clear, effective, and supports the overall safety policy. To ignore one component is to underestimate the importance of the plan so let’s discuss each of them in detail.
1. The Purpose of the Plan - Purpose is the driving force behind employee “buy-in” and gives clarity as to why the plan exists. It should be focused and specific to the plan, yet able to support the strategic objectives of the safety policy as a whole. This is not the time to mince words. The purpose should be clear, definitive, and void of ambiguous language that could confuse the reader. The Toolbox Talk identifies the five criteria that any machine/equipment safety and guarding plan should meet in order to be relevant and to ensure that a quality plan is being created. Meeting those criteria will serve as the foundation of your purpose statement.
2. Administrative Duties - Administration of a safety policy is an ongoing process for safety coordinators and management. There are a number of factors that must be taken under advisement when maintaining, enhancing, or modifying your company’s plan. This section should not be a mind numbing cascade into the minute details of administrative work, rather it should be a statement of the role an administrator plays in facilitating the plan’s execution. The Toolbox Talk identifies six questions that an administrator should be prepared to answer. Documentation of that accountability is what’s required in this section of the plan.
3. Listing of Machine and Equipment – This section is fairly straightforward. It is important to identify what machinery and equipment is applicable to this plan so employees are aware.
4. Pre-operational Procedures – This section states the procedures that must be undertaken before operating the machines and equipment under the purview of this plan. This section should identify specific tasks to be completed before any operation is initiated.
5. Operating Procedures – The importance of properly documenting how machines and equipment are to be used is the heart of this document. Poor operating procedures can lead to accidents and injury. Conveying this importance within the document is paramount. Being right is equally so.
6. Training Program – The training, education, and certification information is outlined in this section. An employee should be able to look at this section and identify the next step in improving his or her skills as an operator.
7. Inspection Procedures – Routine inspections of machinery and equipment are instrumental in promoting safety and preventing injury. This plan requires an inspection process and documentation of who completes those tasks.
8. Recordkeeping Practices – Inspections, certifications, incidents, and maintenance schedules are only some of the things that a company requires documentation of. This plan doesn’t require an exhaustive listing of tasks involved in recordkeeping; rather, it is an acknowledgement that the operation of machines and equipment is a recorded process.
9. Disciplinary Guidelines – Awareness and respect for this plan should be considered conditions of employment just like showing up to work with your shoes on. A company is best served by reserving the right to issue disciplinary warnings up to, and including, termination should it be deemed an appropriate response by management.
10. Evaluation – Evaluation of the plan, itself, is a healthy regulatory process for the company to undertake. This section incorporates those intentions into the plan.
Follow this outline and the boss will be a happy camper and your employees will remain safe! Check out the Toolbox Talks available at www.asa.net. One is geared toward program development and it offers some helpful hints and guidelines on creating your own machine/equipment safety and guarding plan. The other is geared for your employees. OSHA also has developed two e-tools that may prove useful. They can be found at www.osha.gov/SLTC/etools/machineguarding/index.html.
This article was written in conjunction with participants in the OSHA and ASA Alliance. It does not necessarily reflect the official views of OSHA or the U.S. Department of Labor. This article provides general guidelines for voluntary use by employers and is not intended to provide all necessary safety information and precautions for specific workplace operations and situations. ASA assumes no responsibility or liability for the use of the information provided.