ANNUAL VALIDATION AUDIT
Safeguarding Systems Require an Annual Validation Audit
Machinery without proper safeguarding, or improperly safeguarded machinery can present ongoing risk to machine operators. Along with injuries, machine accidents can lead to expensive repairs, diminished company morale, costly regulatory fines and lawsuits, higher insurance premiums, and the redirection of financial resources.
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Since 1971, we’ve developed customized safeguarding solutions to help companies of all sizes protect their employees and machinery by meeting both OSHA regulations and ANSI standards. In addition to our more than 10,000 safeguarding products, we offer valuable services such as risk and machine safeguarding assessments and emergency response, along with training resources to educate professionals on the most current regulations.
Our more than fifty years of experience has taught us that machine safety is an on-going process. This is why Rockford Systems is now offering our Annual Validation Audit (AVA). The Rockford Systems machine safeguarding experts that would conduct your Annual Validation Audit will identify gaps in your organization’s compliance status that will protect the investment you’ve made in safeguarding your equipment to keep your employees safe from injuries. Correcting deficiencies in machine safeguarding found during an audit also demonstrates a good-faith effort towards safety to OSHA regulators and other agencies that may inspect your facility. Larger organizations may perform validation audits 2-3 times a year due to their recognition of an audit’s business value.
Additionally, conducting validation audits satisfies ANSI requirements for mandatory “periodic testing.” In 2019, ANSI published its revised B11.19: Performance Requirements for Risk Reduction Measures: Safeguarding and Other Means of Reducing Risk. ANSI B11.19 states in section 11.3.4 Inspection and maintenance, that the user “shall verify the risk reduction measure(s) is maintained and inspected for the initial training and continued competency of personnel responsible for the maintenance and inspection of the risk reduction measure(s).” It goes on to state “the user shall establish a procedure for the inspection and testing of the risk reduction measure(s), perform periodic testing on a regular basis, and document the results.” It is generally understood that “periodic testing on a regular basis” refers to at least annual testing. Most, if not all, OEMs recommend that their equipment be inspected at least once a year, if not more frequently.
So, as we enter the new year, ask yourself: Is an audit right for you? If you can answer “yes” to one or more of the following questions, you may want to schedule an Annual Validation Audit today.
Take a moment to answer the following three questions.
If you can answer “yes” to one or more, you should conduct or schedule an annual validation audit.
Do you know if the machine safeguarding systems in your facility are still in compliance with OSHA regulation, or ANSI and NFPA 79 standards?
Consensus standards are continually reviewed, revised, rewritten, or re-affirmed to address emerging technologies. Keep in mind that ANSI and NFPA 79 standards are revised more regularly than OSHA’s regulations.
An annual audit by Rockford Systems provides on-going compliance with regulations /standards and risk reduction goals.
Like any industrial equipment, safeguarding devices can degrade and eventually fail over time if not properly maintained. Also, machine operators have been known to tamper with guards if they feel the guards are slowing production.
To ensure the integrity of machine safeguards, a proactive and preventative maintenance program needs to be established based upon the manufacturer’s recommendations, and good engineering practices. Visual inspections, function testing, and auditing help to identify equipment in need of maintenance.
Any number of changes can occur to a safeguarding system that may heighten the potential for injuries. Employees may never have been given proper training, a part may have been removed during maintenance and never replaced, or the entire system may have been installed or removed and re-installed incorrectly.
Any of these issues can lead to safeguarding equipment becoming less effective, and all can be identified during an Annual Validation Audit.
Original equipment manufacturers (OEM) do not necessarily address all hazards on the new machines you put on your plant floor. Regardless of what an OEM provides to you, it’s important to remember that it is the owner’s responsibility to perform a risk or machine safeguarding assessment on newly installed machines to determine all hazards and remediation measures.
What about alterations? Have you made changes to an existing piece of machinery, or your production processes? If so, machine incorrectly applied modifications could create an additional risk.
Also, if you’ve installed a pre-owned or used equipment, be aware that this older equipment is not exempt from current regulations and standards, and needs to be properly safeguarded before brought into use.
An Annual Verification Audit will identify these issues before they lead to an accident, or become an OSHA violation.
An Annual Validation Audit involves a combination of visual inspections, discussion, document reviews, and function testing performed by a highly experienced, knowledgeable professional.
Identifying gaps in machine safeguarding is determined using the most current applicable regulations and standards. During the audit each safeguarding system is function tested to ensure that they operate as designed and intended when needed. Your audit team will also determine if the systems have been properly maintained, and that efforts have not been made to modify or bypass them.
Once an audit is completed, Rockford Systems provides a detailed report highlighting deficiencies along with recommendations for corrective actions needed to bring the equipment back into compliance, if necessary, along with a full proposal.
Start the new year off right by contacting Rockford Systems to schedule an Annual Validation Audit. There is no better way to protect your safeguarding investment.
ANSI B11.19 4.2.1 The user shall be responsible for ensuring that risk reduction measures are provided, integrated, installed, maintained, and used in accordance with this standard.
When machines are ordered/purchased without risk reduction measures, the user shall provide risk reduction measures as determined by this standard, the base ANSI B11 Standard, or machine-specific “base” (type-C) safety standards and shall be based on a risk assessment.
ANSI B11.19 4.2.2 The user shall be responsible for ensuring that supervisors, operators, maintenance, and service personnel are trained in the proper installation, adjustment, operation and maintenance of the risk reduction measures, within the scope of their work activity.
ANSI B11.19 6.1.6 Risk reduction measures shall be inspected, checked, tested or adjusted at regular intervals according to the supplier’s recommendation and the user’s established procedures. All necessary adjustments, maintenance and repairs shall be completed before operating the machinery.
Many, if not most, companies don’t have the internal resources or expertise to perform an Annual Validation Audit, let alone implement corrective actions for non-complaint conditions. Annual Validation Audits conducted by Rockford Systems will help mitigate these safety issues in real time. Call us at 800-922-7533 to schedule your audit.
Alternative Types of Assessments
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