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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Research amassed by the Occupational Safety and Health Association (OSHA) indicates that the primary source of industrial machine accidents is unsafe working conditions. The lack of machine guarding is listed as one of OSHA’s Top Ten most cited violations, year after year.
OSHA 1910.212 and ANSI (American National Standards Institute) B11-series Safety Standards help us to understand that recognized machine hazards need to be either removed, or controlled to a tolerable level of risk. Specifically, the ANSI B11 series standards provide best safety practices for with respect to properly safeguarding machinery and reducing risk.
Since 1971, Rockford Systems has developed customized safeguarding solutions to help companies of all sizes create safety baselines and safeguard their machinery in meeting both OSHA regulations and ANSI standards. In addition to our machine safeguarding products, we also offer machine risk assessments, safeguarding assessments, and emergency response services, plus training resources to educate EHS professionals on the most current safeguarding regulations.
Machine safety is an on-going process. As long as an industrial machine is operating, it represents a potential hazard. Some factors that impact hazard reduction are provision of the correct personal protective and machine safeguarding equipment, personnel changes in the workplace, training, and non-authorized employee equipment modifications. This is why Rockford Systems offers an Annual Validation Audit (AVA). Annual Validation Audits identify gaps in your organization’s compliance status, increases worker awareness of hazards, and it shows commitment to workplace safety, all of which will protect your equipment and employees. Correcting deficiencies in machine safeguarding that are uncovered during an Annual Validation Audit also demonstrates a good-faith effort towards safety to regulatory agencies that may inspect your facility at a later date.
In 2019, ANSI published its revised B11.19: Performance Requirements for Risk Reduction Measures: Safeguarding and Other Means of Reducing Risk. ANSI B11.19 now 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 widely 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. Larger organizations may perform safeguarding audits 2-3 times a year due to their recognition of an audit’s business value.
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 the 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 standards are revised more regularly than OSHA’s regulations.
It is possible a machine safeguarding system that was in full compliance last year may be out of compliance today.
Any number of changes can occur to a safeguarding system that may heighten the potential for injuries. For instance, safeguarding equipment may be intentionally removed, bypassed or tampered with, or re-installed incorrectly. Regular wear and tear or improperly maintained equipment could also lead to safeguarding equipment becoming less effective in some instances. All of these problems could be identified in an Annual Validation Audit.
Sometimes employees find ways to bypass machine safeguards when there’s a perception that they hinder production. When properly designed in respect of the processes where they are being used, machine safeguarding equipment shouldn’t be a hinderance.
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.
Evaluations are made while conducting an Annual Validation Audit through a combination of visual inspections, discussion, document reviews, and function testing. Identifying gaps in your machine safeguarding is determined using applicable regulations and standards.
During the audit each safeguarding system is function tested to ensure that they operate as designed and intended, have been properly maintained, and will identify if efforts have been made to modify or bypass existing machine safeguarding.
Once an audit is completed, the Rockford Systems team provides a detailed report highlighting deficiencies along with high-level recommendations for corrective actions needed to bring the equipment back into compliance, if necessary.
ANSI B22.214.171.124 The user shall document the risk reduction measures.
ANSI B126.96.36.199 The user shall provide maintenance instructions, recommendations, and procedures to maintenance personnel for all risk reduction measures used to protect individuals from the hazards associated with the machine.
ANSI B188.8.131.52 The user shall verify the risk reduction measure(s) is maintained and inspected, and shall arrange for the initial training and continued competency of personnel responsible for the maintenance and inspection of the risk reduction measure(s).
ANSI B184.108.40.206 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.
ANSI B220.127.116.11 Following any maintenance to the risk reduction measure(s), the user shall verify the risk reduction measures(s) performs as intended.
ANSI B18.104.22.168 When the risk reduction measure(s) is removed or disabled
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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