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Tube & Pipe

The politics & price of safety

By Dennis Cloutier, CSP

Above: Designing safeguarding into a machine rather than retrofitting it later is more cost effective.

Reconciling conflicting European and American machinery safety standards

December 2014 - With manufacturing becoming more global, resolving conflicting machinery safety requirements is becoming more relevant. There is confusion between European safety standards for machinery in compliance with the Machinery Directive in the European Union (EU), and U.S. safety standards developed under the direction of the American National Standards Institute (ANSI), which are voluntary consensus standards. 

(Note: For this article, “supplier” refers to the original machine tool manufacturer (OEM); while “user” refers to the purchaser of the machine tool that uses it in the production of its product.)

Let’s look more deeply into this issue by posing a hypothetical scenario. A manufacturer (user) in the United States needs to buy a machine for a new production process. If it buys from a European supplier, it most likely comes fully safeguarded due to European requirements and reflects the added cost for safeguarding. If a similar machine is purchased from a U.S. supplier, it most likely has minimal safeguarding, lacking the specific safeguards at the point of operation, resulting in a less costly machine. Given these options what would most buyers do? What are a user’s responsibilities? Is purchasing from a domestic supplier more affordable?

Users are experiencing this situation more frequently as they shop around the world for the best production machine to meet their needs. Some buy on price, others on features, and most fall somewhere in between the two.

Safety requirements written in compliance with the EU Machinery Directive place the responsibility on the supplier to provide safeguarding protection for the foreseeable use of the machinery they manufacture. These requirements include all identified hazards, including the point of operation (where the piece part is worked by the machine), thus fully safeguarding the machine before it is shipped to the user. 

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In the 1990s, U.S. suppliers active in the European market began to adjust to this issue and continue today to make accommodations in their designs to ship a machine into the EU. They had to do this because, here in the United States, the situation is different. The American written (ANSI) machinery safety standards did not include as comprehensive a requirement as the EU standards for safeguarding. And, the market did not demand expansive safeguarding, including point-of-operation safeguarding, to be provided by the supplier. Suppliers typically provide what the market demands. This was particularly true for metal fabricating machines such as pipe and tube benders, power presses, press brakes, steel coil processing machinery, large vertical turning machines, and horizontal boring machines. The intent in the EU was and still is to require that machinery be safe as it comes from the supplier’s manufacturing plant. In the U.S. users generally provide their own safeguarding in order to comply with OSHA regulations.

ANSI machine tool standards stipulate safeguarding as an umbrella term. It includes guards, safety devices, barriers, perimeter guarding, awareness barriers, warning signs and signals, hazard markings, training and other administrative controls. ANSI B11.0 and ANSI B11.19 outline distinguishing characteristics of these types but do not address the specific application. Other machine-specific standards are addressed, such as B11.15 for tube and pipe benders and B11.1 for mechanical power presses. Guards provide the highest level of protection as they prevent access to the hazard zone. They are applied to the spot location of a hazard, such as in-running nip points at chain and sprocket, or near a rotating shaft. Perimeter guarding is generally applied to an area, such as at the discharge of a tube bender, along the length of a coil processing line, or at the infeed station of a power press. 

The U.S. has customarily approached safeguarding differently than the Europeans by designing and building machine tools to meet the customers’ safety needs. For decades suppliers would safeguard drive train components, in-running nip points and other similar hazards, but generally they did not place safeguarding at or around the point of operation. And not by coincidence, the ANSI machine tool safety standards reflected this custom and practice, the justification being that the user provides the safeguarding for the point of operation, because it is the user who determines the specific use of the machine on any given day. 

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In the U.S., federal law places the responsibility on the user (employer) to maintain a workplace free from known hazards. In 1970, Congress passed the Occupational Safety and Health Act. In doing so, the Occupational Safety and Health Administration was created with the authority to develop and enforce national safety standards. In short, the law and the agency established the requirement that users safeguard the machines they operate. OSHA standards are not ANSI standards, and though some OSHA regulations were born from ANSI standards that existed in 1970, they are distinct and separate rules.

Safeguard timing

Many users have learned over the past decade that it is almost always less expensive to design safeguarding into the machine from the beginning rather than retrofit it later. Today, it is also important to follow this model because as the purchaser, confidence that safeguarding is properly designed to be compatible with the machine is a critical element in overall safety.

When safeguarding is added after the machine is built, important elements are often missed. The ANSI B11 standard required users to perform a risk assessment to examine machine operations and identify hazards. The standard also requires suppliers to do the same, except for the point of operation. There are exceptions based on the machine type. It is difficult for the supplier to foresee the daily use of the most versatile machines—especially pipe and tube benders, press brakes and presses. The user that is developing a multi-machine process has little option but to take this risk assessment on or outsource the task to a machine integrator, which specializes in providing this service. But as a user in the U.S., for a standalone machine, it is recommended to get the safeguarding up front from the supplier rather than integrate it after delivery.

Safeguarding newer equipment can also bring to light existing hazards on older machinery. For example, users are often aware of how different a newer machine looks when installed in their facility next to a similar machine that is 20 or more years older. Yet, surprisingly, they often see no need to modify or upgrade the older machine to have the additional guarding, hazard marking or warning signs that they see on the new machine. It prompts the question: How effective are users, usually smaller companies, at conducting risk assessments? How many hazards would they fail to see because they’re operating the equipment daily without awareness of present-day safeguarding equipment? Many manufacturing shops lack knowledge of the hazards inherent with older machinery and/or the means to provide protection for their personnel. Thus, how effective would their risk assessment be? 

Some users, after purchasing a machine for a U.S. supplier, will decide not to spend the money upgrading the safeguarding on new equipment because their other (older) machines are not safeguarded and they have not had issues with them in the past. It is unfortunate that they would risk the health of their employees and, under some circumstances expose, themselves to the attendant liability.

When comparing suppliers that include a safeguarding package versus those that do not, ask those that don’t to provide it upfront and to resubmit a proposal that includes a complete safeguarding package. 

Using the pipe bender as an example, ensure the safeguarding encloses comparable areas. With these machines, the supplier knows the maximum area within which the largest workpiece moves as it is formed. Make sure both proposals are similar. The supplier may have calculated area that is much larger than originally intended based on your product mix. This is the time to have that conversation. Floor space is always at a premium and it is sometimes necessary to work with the supplier to ensure the safeguarded work area is compatible with a space situation. But, above all, do everything possible to have safeguarding provided with the machine purchase.

The end result is a machine that will do everything you need it to do, your personnel will continue to have a safe place in which to work and you have eliminated a major risk to production. FFJ

Dennis Cloutier has worked for industrial companies for 40 years. While employed by Cincinnati Inc. for 29 years, he provided factory support on the company’s machine tool products in hundreds of manufacturing facilities across the United States and Canada. 

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