Lack of Machine Guarding Again Named to OSHA’S Top 10 Most Cited Violations List

Every year around this time, the awards season kicks off with the Emmys, Golden Globes and the grand daddy of them all, the Oscars, eagerly announcing their lists of nominations. At the same time — and on a far more somber note — another roll call is issued, this one from the Occupational Safety & Health Administration (OSHA). Unlike Hollywood’s awards celebrations, however, no one wants to be nominated for OSHA’s Top Ten Most Cited Violations list, let alone take home the top prize.

OSHA revealed its 2017 Top 10 list at the National Safety Congress & Expo in the Indiana Convention Center. The top ten are:

1. Fall Protection – (1926.501): 6,072 violations
2. Hazard Communication (1910.1200): 4,176 violations
3. Scaffolding (1926.451): 3,288 violations
4. Respiratory Protection (1910.134): 3,097 violations
5. Lockout/Tagout (1910.147): 2,877 violations
6. Ladders (1926.1053): 2,241 violations
7. Powered Industrial Trucks (1910.178): 2,162 violations
8. Machine Guarding (1910.212): 1,933 violations
9. Fall Protection – Training Requirements: 1,523 violations
10. Electrical – Wiring Methods (1910.305): 1,405 violations

While reviewing the list, it is important to remain aware that the Federal Occupational Safety & Health Administration (OSHA) is a small agency. When tallied up to include its state partners, OSHA only has 2,100 inspectors who responsible for the health and safety of 130 million American workers, employed at more than 8 million work sites. This translates to about one compliance officer for every 59,000 workers. As a result, some serious injuries are not reported and thousands of potential violations go without citation or fines. In fact, numerous studies have shown that government counts of occupational injury are underestimated by as much as 50 percent. Employers are required to record all injuries meeting the OSHA’s ‘recordable injury’ criteria (except minor first-aid cases) on the OSHA 300 Log, and those meeting the ‘reportable’ criteria (e.g., hospitalizations or deaths), are to be reported to OSHA immediately, or within 24 hours of occurrence, as per the criteria defined in 29 CFR 1904. But it doesn’t mean all of them do.

MACHINE (UN)SAFEGUARDING IN TOP 10 MOST CITED VIOLATIONS
The absence of required machine safeguarding remains a perennial member of OSHA’s Top 10 Most Cited Violations, and 2017 was no exception. It was named number eight on the list with a total of 1,933 violations. These violations refer to OSHA 1910.212 for failing to have machines and equipment adequately guarded. Any machine part, function, or process that might cause injury should be safeguarded. When the operation of a machine may result in a contact injury to the operator or others in the area, the hazard should be removed or controlled.

A lack of machine safeguarding also held the dubious distinction of making the list of OSHA’s ten largest monetary penalties for the year — not once but four times. In fact, the largest proposed monetary penalty, a staggering $2.6 million (USD), arose from an incident where a worker was crushed to death while clearing a sensor fault in a robotic conveyor belt. OSHA alleges that the company failed to use energy control procedures to prevent robotic machinery from starting during maintenance. The manufacturer also was cited for exposing employees to crushing and amputation hazards as a result of improper machine guarding, plus failing to provide safety locks to isolate hazardous energy.

Despite these headline fines, the repercussions for employers putting workers in harm’s way remain small under the 1970 Occupational Safety and Health Act. The average federal fine for a serious workplace safety violation was $2,402 in fiscal year 2016, according to the most recent report by the AFL-CIO. And the median penalty for killing a worker was $6,500.

According to the most recent Bureau of Labor Statistics data, manufacturing plants reported approximately 2,000 accidents that led to workers suffering crushed fingers or hands, or had a limb amputated in machine-related accidents. The rate of amputations in manufacturing was more than twice as much (1.7 per 10,000 full-time employees) as that of all private industry (0.7). The bulk of these accidents occurred while removing jammed objects from a machine, cleaning or repairing the machine, or performing basic maintenance. These injuries were all largely preventable by following basic machine safeguarding precautions. Rockford Systems is committed to helping organizations reduce injuries and fatalities due to a lack of or non-compliant machine safeguarding. By creating a culture of safety in the workplace, Rockford Systems can help plant managers significantly reduce the number of on-the-job injuries and fatalities that occur annually, plus guard against hefty fines, lost production and increased insurance premiums.

Which leads to the question… “Where do we begin?”

TRAINING AND EDUCATION

Ignorantia juris non excusat (“ignorance of the law excuses not”). Recognizing that education is key to safety, Rockford Systems has offered its Machine Safeguarding Seminars for more than two decades. Thousands of safety professionals have attended the seminars from industries as diverse as aerospace and metal fabrication, to government and insurance.

Held ten times a year at our Rockford, Illinois headquarters, the 2.5 day seminars address key topics in safeguarding with a focus on OSHA 29 CFR and ANSI B-11 standards as they relate to specific machine applications and production requirements. Safeguarding equipment, both old and new, is not only explained in depth in the classroom, but demonstrated under power on the shop floor. Most of these machines are equipped with more than one type of safeguarding product so that attendees can see how different guards and devices can be applied.

Roger Harrison, Director of Training for Rockford Systems and an industrial safeguarding expert with over 25,000 hours of training experience, conducts the Machine Safeguarding Seminar.

>Another valuable educational resource is OSHA-10 General Industry and OSHA-30 General Industry training courses, both of which cover machine guarding. All of our training can be provided at your site, if preferred. To learn more about the Rockford Systems training curriculum, please visit https://www.rockfordsystems.com/seminars/

Rockford Systems also provides a variety of FREE machine safeguarding resources for your organization. Please visit our RESOURCES page to find videos, blogs, quick reference sheets, and more or visit our YouTube channel to download past webinar recordings.

ASSESSMENTS
If your organization is interested in safeguarding solutions, consider a Machine Risk Assessment or Machine Safeguarding Assessment as the critical first step in any machine guarding process as outlined in ANSI B11. Most assessments, but not all, follow the basic steps outlined below.

Step 1 – Provide Machine List
To get started, please provide Rockford Systems a list of all machines (manufacturer, model number, and machine description of each machine) to be assessed. This machine list is needed to determine the estimated resource requirement for the onsite audit. Upon receipt of your machine list, an Assessment Proposal will be provided, generally within 24 hours of receipt. Please email your machine list and any machine photos (optional) to sheryl.broers@rockfordsystems.com.

Step 2 – Schedule Onsite Visit
During the assessment, a machine safeguarding specialist will visit your site and conduct a complete audit of all machines identified on the list and evaluate their compliance in five guarding areas (Safeguards, Controls, Disconnects, Starters, and Covers). The assessment is based on OSHA 1910.212 General Requirements (a)(1), ANSI B11 Safety Standards for Metalworking, ANSI/RIA R15.06-2012 Safety Standards for Industrial Robots, and NFPA 79. If Rockford Systems, LLC has additional specific safeguarding requirements above and beyond OSHA 1910.212 and ANSI B11, please provide them before the site visit and we will incorporate them into the assessment.

Also, during the assessment, we may request copies of electrical, pneumatic and/or hydraulic schematics and operator manuals for specific machines. This information is needed for our Engineering Department to review the control circuit for electrical compatibility of equipment being offered, to verify control reliability of the control circuit, to determine interfacing requirements of suggested equipment. If requested, this information would be needed before advancing to Step 3 below.

Step 3 – Receive Compliance Report and Safeguarding Project Proposal
Upon completion of the assessment, a Compliance Report and Safeguarding Project Proposal will be provided to that identifies where each machine is in, or not in, compliance with the above stated regulations and standards. Where not in compliance, we will suggest guarding solutions to bring the machines into compliance, along with associated costs and timeframes.

We look forward to assisting your organization with its safeguarding needs. A team member will call you within 24 hours to further discuss your needs and applications. We are here to help businesses large and small address machine safety challenges and to remove the burden of managing the growing legal complexity of OSHA, ANSI and NFPA requirements from simple turnkey solutions to build-to-spec customized solutions.

Please contact sheryl.broers@rockfordsystems.com or call 1-815-874-3648 (direct) to get started on an assessment today.

PRODUCTS
If you are looking for Machine Safeguarding Products, please visit our PRODUCTS page that offers over 10,000 safeguarding solutions for drill presses, grinders, lathes, milling machines, press brakes, power presses, radial arm drills, riveters and welders, robots, sanders, saws and more.

RETURN ON INVESTMENT
Not sure if the investment in machine safeguarding provides a return on the investment (ROI), it absolutely does and we can help you calculate it. Please read our detailed blog post on this topic.

For more information on how avoid machine injuries and fatalities, please visit www.rockfordsystems.com.

Calculating a Safeguarding ROI

In the United States, workers operating or maintaining industrial machinery suffer more than 18,000 amputations, crushed fingers and other traumatic injuries each year. While these injuries vary greatly, the majority of cases do have one thing in common: the injury was largely preventable if machine safeguarding equipment had been in-place, or would have been far less severe.

Many employees, unions and worker advocates may well ask, “Why do we need a safeguarding business case?” “Don’t employers have a responsibility for providing a safe and healthful workplace for their employees?” Although U.S. organizations understand that machine safeguarding is the law and that protecting human life is socially responsible, each company must answer the return on investment (ROI) question their own way. Where does safeguarding fit into a business strategy? Can safeguarding be quantified by using cost-benefit financial analysis? To get to those answers we need to look at both sides of the ledger, comparing the cost of an accident versus the cost of preventing it.

WHAT DOES A MACHINE ACCIDENT COST?
Insurance studies indicate machine safeguarding provides an opportunity for businesses to reduce bottom-line operating costs by eliminating both the direct and indirect costs of an accident, while improving productivity and employee morale. But just how much can be saved? Liberty Mutual reported in its annual Workplace Safety Index that U.S. employers spent $48.6 billion for wage and productivity losses, medical expenses and administrative expenses for workers hurt on the job. This is roughly equivalent to the annual sales of Cisco, Pfizer or FedEx. A study by Colorado State University set the total direct and indirect cost of workplace injuries at a staggering $128 billion.

Safeguarded Press

Direct costs of an accident refer to out-of-pocket expenses like hospital and medical bills. They also include the loss of a worker’s time because of the accident, the lost productivity by the machine involved in the accident being idled or requiring repairs, as well as the other machines further down the production line being shut down. Costs continue to cascade throughout the company with overtime required to make up the lost productivity and new workers who need to be hired and trained. The National Safety Council (NSC) estimates that lost time alone associated with the average injury costs nearly $30,000.

However, costs related to an injury do not end there, as an accident will influence indirect costs far outside company walls. Analysis of most accidents reveal that the actual total cost can range from four to ten times the visible, direct cost stated by an insurance company. For example, a single accident can result in OSHA fines up to $100,000 per machine or more if the violation is found to be willful. In 2010, 24 percent of OSHA’s Top 10 citations for manufacturing dealt with machine guarding violations, resulting in more than $6 million in proposed penalties. In addition, insurance rates can rise dramatically or coverage can be dropped entirely. Investments targeted for company growth may need to be diverted to cover the costs of the accident, while employee morale and productivity can experience a significant drop, and the company’s brand and reputation will likely be damaged by negative publicity. Finally, there are the legal fees, plus management time spent dealing with regulators and attorneys.

Safeguarded Mill Drill
And while it is not calculated as an indirect cost, a poor safety record can make the difference between a company winning and losing bids, especially with government contracts. A plant with a singularly bad reputation for safety may also find itself unable to attract workers at all or may have to pay wages well above market value to do so. Also, if the machine where a serious accident occurred is unique and is locked out for investigation or until the safeguarding deficiency is abated, the company may need to outsource the work at a much higher cost. It’s also possible that the work is so specialized that it’s impossible to outsource and therefore the company loses the business.

DO THE MATH
OSHA’s $afety Pays website (www.osha.gov/dcsp/smallbusiness/safetypays) makes it easy for organizations to calculate direct and indirect costs of an accident. As an example, let’s assume a fictional company with annual sales of $5 million and an 8% pre-tax profit margin has an accident involving an employee whereby his hand was entangled in a drill press.

By using insurance company claims data, $afety Pays can calculate that the crushing accident will cost that company, on average:
• Direct Cost: $56,557
• Indirect Cost: $62,212
• Estimated Total Cost: $118,769

Safeguarded Lathe
By entering profit margin information, $afety Pays will also project the additional sales required to recover the costs of the injury. In this instance, additional sales revenue necessary to cover costs is $1,484,612 based on the 8% profit margin or approximately one third of annual sales. If pre-tax margins are less, the sales impact is even greater.
On the other side of the ledger is the cost to safeguard the machine involved in the accident. For the purpose of this discussion, let’s assume that the same fictional company had an onsite risk assessment performed by a reputable firm that surveyed ten machines on the plant floor at a cost of $5,000, or $500 per machine. Next, assume that the drill press had been safeguarded per OSHA regulations and ANSI standards at a total cost of $1,000. Adding in its prorated share of the risk assessment, total cost to safeguard the drill press would be $1,500, a figure that compares very favorably to the estimated $118,769 cost of the accident.

HUMAN CAPITAL AS ROI
A poll by Liberty Mutual Group insurance showed that the majority of executives surveyed (61%) reported that for every one dollar spent on safety, three dollars is saved. And nearly all (95%) said workplace safety had a positive effect on financial performance. OSHA estimates a 6:1 ratio for saved dollars for every one dollar invested in safety, twice Liberty Mutual’s 3:1 ratio.

Of course, if a company could be guaranteed a positive return on their safety investment, more than half the machines in the United States today would not be operating unprotected. Convincing upper management to commit tens of thousands of dollars on machine safeguarding when a return may not be seen for years can be a hard sell. In this situation, safety professionals should stress that although cost savings are a motivator, safety’s biggest ROI comes in the form of human capital. Money savings from fewer injuries, increased productivity, and higher morale are all additional benefits.

CONCLUSION
Whether driven by the law or social responsibility or the need for a positive ROI, most organizations embark on a quest to make their workplaces safe. The business case for machine safeguarding is solid. By comparing the installation cost of safeguarding over the productive life of a machine versus the direct and indirect costs of even a single accident, it becomes clear that safeguarding makes sound business sense and should be a cornerstone of an organization’s safety goals and objectives.