Major technological changes have taken place in manufacturing plants during the past decade, and safety regulations have evolved in tandem. The rise of automated robotic processes throughout distribution centers and manufacturing facilities has increased productivity but has subsequently created a new slate of safety concerns and hazardous situations.
Written to be compliant with international standards already in place in Europe, the updated RIA 15.06 regulation is a good starting point for addressing some of these industrial robotic safety hazards. Part of this modernized standard requires better hazard identification, accounting for not only robot motion, but also the task being performed. And although OSHA will often reference RIA 15.06 and other ANSI specifications as best practices, the governing body still lacks specific regulations in its books for various automated operations.
For example, take a look at a seemingly harmless operation that’s become nearly ubiquitous at every loading dock or at the end of every assembly line in America – automated stretch-wrap machines. As with most other industrial processes, what began as a manual operation is now commonly automated. Workers who previously had the arduous task of bending, pulling, and moving stretch wrap around a pallet now just press a button once a load is placed on a pallet.
Workers who no longer have to stoop and circle a pallet of product aren’t likely to complain about potential safety hazards. However, this particular aspect of plant operation has long been overlooked as a hazard. With suppliers adding more automated functions to their floors (including intelligent conveyors, AGVs and AS/RS systems), it’s critical for safety methodology to be similar to that of other automated or robotic processes and compliant with current standards.
Currently, these machines should default to the general requirements for all machines per OSHA 29 CFR 1910.212 (a) (3) (ii), which states that the point of operation of machines whose action exposes an employee to injury shall be guarded. The good news is that stretch-wrap machine operation can be isolated with proper guarding devices such as fixed fencing and automated barrier doors.
Although there isn’t a specific set of safety guidelines for automated stretch-wrap machines, every operation should at least uphold the OSHA General Requirements of All Machines and companies should ensure the safety of their employees. OSHA’s General Duties Clause stipulates that each employer and employee recognizing a hazard must comply with occupational safety and health standards contained within this act.
RIA 15.06 was modeled after European standards, and the globalization of codes and regulations is a fact of life. It’s only a matter of time before OSHA adopts a standard similar to the European standard BS EN 415-6, which specifically references automated stretch-wrap machines.
In the case of stretch-wrapping equipment, employers should consider ways to improve safety through guarding or containment per 29 CFR 1910.212(a)(3)(ii) General Requirements of All Machines.
These standards should be upheld at all times, but unfortunately, it’s common for safety breakdowns to occur in plants. Among the reasons for these are the following:
- Machinery is not designed or tested with proper safety systems or interlocks in place
- Safety features are removed by the end user, employee, or maintenance personnel because they are cumbersome or get lost during routine maintenance
- Employees lack proper training on procedural use of process
- Production takes precedent over safety
- Employer does not proactively identify safety issues that might arise
- A lack of regular safety assessments
For complete safety in any automated workplace, the culture around safety must always be the primary focus. In some ways, RIA guidelines are already compelling this safety culture by calling for organizations to conduct risk assessments.
To enhance safety, risk assessments must be performed whenever new equipment is implemented into a plant. It’s also a good practice to conduct risk assessments periodically to make sure safety standards are upheld.
Understanding the hierarchy of safety also is essential in correcting potential safety hazards. Personal protective equipment (PPE) for employees is the most convenient option, but it is the least effective at protecting workers around automated equipment and machinery. Even after training, there’s no way to guarantee that workers will wear or use their PPE.
The same concerns apply to administrative controls such as warning signs and yellow lines. Although these visual cues are useful communication tools, their warnings aren’t always followed. Upgrading safety to the use of engineering controls like light scanners or light curtains can isolate hazards and provide automatic shutdowns, but the inertia of many operations can still lead to unsafe situations, well after the machine is shut down.
There’s always the option to substitute the human element and completely automate the entire process or do it entirely differently. However, this is not always possible for various reasons, including prohibitive costs.
Eliminating the risk is the most difficult option, but it’s the most effective strategy in protecting workers. In the automated stretch-wrap example, one of the most successful ways to accomplish this is with an automated barrier door and surrounding fence. In this situation, the fence restricts workers from entering the cell, while the automated high-speed barrier door serves as an efficient way in and out of the cell when operation inside the cell has ceased.
Best practices contained within RIA 15.06 and other machine-specific ANSI standards are a good starting point to stay ahead of enforceable OSHA regulations. Although general safety guidelines outlined by OSHA should apply to automated stretch-wrap machines, it likely will be only a matter of time before specific standards catch up.
Investing in a safety plan today, whether it’s an automated barrier door or other safety initiative, can help protect machine operators, allow facilities to adhere to lean manufacturing principles and, ultimately, boost the bottom line.