Understanding the Hierarchy of Controls

This entry is part 2 of 3 in the series Hierarchy of Controls

Risk assessment is the first step in reducing the risk that your customers and users are exposed to when they use your products. The second step is Risk Reduction, sometimes called Risk Control or Risk Mitigation. This article looks at the ways that risk can be controlled using the Hierarchy of Controls. Figure 2 from ISO 12100-1 (shown below) illustrates this point.

The system is called a hierarchy because you must apply each level in the order that they fall in the list. In terms of effectiveness at reducing risk, the first level in the hierarchy, elimination, is the most effective, down to the last, PPE*, which has the least effectiveness.

It’s important to understand that questions must be asked after each step in the hierarchy is implemented, and that is “Is the risk reduced as much as possible? Is the residual risk a) in compliance with legal requirements, and b) acceptable to the user or worker?”. When you can answer ‘YES’ to all of these questions, the last step is to ensure that you have warned the user of the residual risks, have identified the required training needed and finally have made recommendations for any needed PPE.

*PPE – Personal Protective Equipment. e.g. Protective eye wear, safety boots, bump caps, hard hats, clothing, gloves, respirators, etc. CSA Z1002 includes ‘…anything designed to be worn, held, or carried by an individual for protection against one or more hazards.’  in this definition.

Risk Reduction from the Designer's Viewpoint
ISO 12100:2010 – Figure 2

 

Introducing the Hierarchy of Controls

The Hierarchy of Controls was developed in a number of different standards over the last 20 years or so. The idea was to provide a common structure that would provide guidance to designers when controlling risk.

Typically, the first three levels of the hierarchy may be considered to be ‘engineering controls’ because they are part of the design process for a product. This does not mean that they must be done by engineers!

We’ll look at each level in the hierarchy in detail. First, let’s take a look at what is included in the Hierarchy.

The Hierarchy of Controls includes:

1)    Hazard Elimination or Substitution (Design)
2)    Engineering Controls (see [1, 2, 8, 9, 10, and 11])

a)    Barriers

b)    Guards (Fixed, Movable w/interlocks)

c)    Safeguarding Devices

d)    Complementary Protective Measures

3)    Information for Use (see [1, 2, 4, 7, 8, 12, and 13])

a)    Hazard Warnings

b)    Manuals

c)    HMI* & Awareness Devices (lights, horns)

4)    Administrative Controls (see [1, 2, 4, 5, 7, and 8])

a)    Training

b)    SOP’s,

c)    Hazardous Energy Control Procedures (see [5, 14])

d)    Authorization

5)    Personal Protective Equipment

a)    Specification

b)    Fitting

c)    Training in use

d)    Maintenance

*HMI – Human-Machine Interface. Also called the ‘console’ or ‘operator station’. The location on the machine where the operator controls are located. Often includes a programmable screen or operator display, but can be a simple array of buttons, switches and indicator lights.

The manufacturer, developer or integrator of the system should provide the first three levels of the hierarchy. Where they have not been provided, the workplace or user should provide them.

The last two levels must be provided by the workplace or user.

Effectiveness

Each layer in the hierarchy has a level of effectiveness that is related to the failure modes associated with the control measures and the relative effectiveness in reducing risk in that layer. As you go down the hierarchy, the reliability and effectiveness decrease as shown below.

Effectiveness of the Hierarchy of ControlsThere is no way to measure or specifically quantify the reliability or effectiveness of each layer of the hierarchy – that must wait until you make some selections from each level, and even then it can be very hard to do. The important thing to understand is that Elimination is more effective than Guarding (engineering controls), which is more effective than Awareness Means, etc.

1. Hazard Elimination or Substitution

Hazard Elimination

Hazard elimination is the most effective means of reducing risk from a particular hazard, for the simple reason that once the hazard has been eliminated there is no remaining risk. Remember that risk is a function of severity and probability. Since both severity and probability are affected by the existence of the hazard, eliminating the hazard reduces the risk from that particular hazard to zero. Some practitioners consider this to mean the elimination is 100% effective, however it’s my opinion that this is not the case because even elimination has failure modes that can re-introduce the hazard.

Failure Modes:

Hazard elimination can fail if the hazard is reintroduced into the design. With machinery this isn’t that likely to occur, but in processes, services and workplaces it can occur.

Substitution

Substitution requires the designer to substitute a less hazardous material or process for the original material or process. For example, beryllium is a highly toxic metal that is used in some high tech applications. Inhalation or skin contact with beryllium dust can do serious harm to a person very quickly, causing acute beryllium disease. Long term exposure can cause chronic beryllium disease. Substituting a less toxic material with similar properties in place of the beryllium in the process  could reduce or eliminate the possibility of beryllium disease, depending on the exact content of the substitute material. If the substitute material includes any amount of beryllium, then the risk is only reduced. If it contains no beryllium, the risk is eliminated. Note that the risk can also be reduced by ensuring that the beryllium dust is not created by the process, since beryllium is not toxic unless ingested.

Alternatively, using processes to handle the beryllium without creating dust or particles could reduce the exposure to the material in forms that are likely to cause beryllium disease. An example of this could be substitution of water-jet cutting instead of mechanical sawing of the material.

Failure Modes:

Reintroduction of the substituted material into a process is the primary failure mode, however there may be others that are specific to the hazard and the circumstances. In the above example, pre- and post-cutting handling of the material could still create dust or small particles, resulting in exposure to beryllium. A substituted material might introduce other, new hazards, or might create failure modes in the final product that would result in risks to the end user. Careful consideration is required!

If neither elimination or substitution is possible, we move to the next level in the hierarchy.

2. Engineering Controls

Engineering controls typically include various types of mechanical guards [16, 17, & 18], interlocking systems [9, 10, 11, & 15], and safeguarding devices like light curtains or fences, area scanners, safety mats and two-hand controls [19]. These systems are proactive in nature, acting automatically to prevent access to a hazard and therefore preventing injury. These systems are designed to act before a person can reach the danger zone and be exposed to the hazard.

Control reliability

Barrier guards and fixed guards are not evaluated for reliability because they do not rely on a control system for their effectiveness. As long as they are placed correctly in the first place, and are otherwise properly designed to contain the hazards they are protecting, then nothing more is required. On the other hand, safeguarding devices, like interlocked guards, light fences, light curtains, area scanners, safety mats, two-hand controls and safety edges, all rely on a control system for their effectiveness. Correct application of these devices requires correct placement based on the stopping performance of the hazard and correct integration of the safety device into the safety related parts of the control system [19]. The degree of reliability is based on the amount of risk reduction that is being required of the safeguarding device and the degree of risk present in the unguarded state [9, 10].

There are many detailed technical requirements for engineering controls that I can’t get into in this article, but you can learn more by checking out the references at the end of this article and other articles on this blog.

Failure Modes

Failure modes for engineering controls are as many and as varied as the devices used and the methods of integration chosen. This discussion will have to wait for another article!

Awareness Devices

Of special note are ‘awareness devices’. This group includes warning lights, horns, buzzers, bells, etc. These devices have some aspects that are similar to engineering controls, in that they are usually part of the machine control system, but they are also sometimes classed as ‘information for use’, particularly when you consider indicator or warning lights and HMI screens. In addition to these ‘active’ types of devices, awareness devices may also include lines painted or taped on the floor or on the edge of a step or elevation change, warning chains, signage, etc. Signage may also be included in the class of ‘information for use’, along with HMI screens.

Failure Modes

Failure modes for Awareness Devices include:

  • Ignoring the warnings (Complacency or Failure to comprehend the meaning of the warning);
  • Failure to maintain the device (warning lights burned out or removed);
  • Defeat of the device (silencing an audible warning device);
  • Inappropriate selection of the device (invisible or inaudible in the predominating conditions).

Complementary Protective Measures

Complementary Protective measures are a class of controls that are separate from the various types of safeguarding because they generally cannot prevent injury, but may reduce the severity of injury or the probability of the injury occurring. Complementary protective measures are reactive in nature, meaning that they are not automatic. They must be manually activated by a user before anything will occur, e.g. pressing an emergency stop button. They can only complement the protection provided by the automatic systems.

A good example of this is the Emergency Stop system that is designed into many machines. On its own, the emergency stop system will do nothing to prevent an injury. The system must be activated manually by pressing a button or pulling a cable. This relies on someone detecting a problem and realizing that the machine needs to be stopped to avoid or reduce the severity of an injury that is about to occur or is occurring. Emergency stop can only ever be a back-up measure to the automatic interlocks and safeguarding devices used on the machine. In many cases, the next step in emergency response after pressing the emergency stop is to call 911.

Failure Modes:

The failure modes for these kinds of controls are too numerous to list here, however they range from simple failure to replace a fixed guard or barrier fence, to failure of electrical, pneumatic or hydraulic controls. These failure modes are enough of a concern that a new field of safety engineering called ‘Functional Safety Engineering’ has grown up around the need to be able to analyze the probability of failure of these systems and to use additional design elements to reduce the probability of failure to a level we can tolerate. For more on this, see [9, 10, 11].

Once you have exhausted all the possibilities in Engineering Controls, you can move to the next level down in the hierarchy.

3. Information for Use

This is a very broad topic, including manuals, instruction sheets, information labels on the product, hazard warning signs and labels, HMI screens, indicator and warning lights, training materials, video, photographs, drawings, bills of materials, etc. There are some excellent standards now available that can guide you in developing these materials [1, 12 and 13].

Failure Modes:

The major failure modes in this level include:

  • Poorly written or incomplete materials;
  • Provision of the materials in a language that is not understood by the user;
  • Failure by the user to read and understand the materials;
  • Inability to access the materials when needed;
  • Etcetera.

When all possibilities for informing the user have been covered, you can move to the next level down in the hierarchy. Note that this is the usual separation point between the manufacturer and the user of a product. This is nicely illustrated in Fig 2 from ISO 12100 above. It is important to understand at this point that the residual risk posed by the product to the user may not yet be tolerable. The user is responsible for implementing the next two levels in the hierarchy in most cases. The manufacturer can make recommendations that the user may want to follow, but typically that is the extent of influence that the manufacturer will have on the user.

4. Administrative Controls

This level in the hierarchy includes:

  • Training;
  • Standard Operating Procedures (SOP’s);
  • Safe working procedures e.g. Hazardous Energy Control, Lockout, Tagout (where permitted by law), etc.;
  • Authorization; and
  • Supervision.

Training is the method used to get the information provided by the manufacturer to the worker or end user. This can be provided by the manufacturer, by a third party, or self-taught by the user or worker.
SOP’s can include any kind of procedure instituted by the workplace to reduce risk. For example, requiring workers who drive vehicles to do a walk-around inspection of the vehicle before use, and logging of any problems found during the inspection is an example of an SOP to reduce risk while driving.
Safe working procedures can be strongly influenced by the manufacturer through the information for use provided. Maintenance procedures for hazardous tasks provided in the maintenance manual are an example of this.
Authorization is the procedure that an employer uses to authorize a worker to carry out a particular task. For example, an employer might put a policy in place that only permits licensed electricians to access electrical enclosures and carry out work with the enclosure live. The employer might require that workers who may need to use ladders in their work take a ladder safety and a fall protection training course. Once the prerequisites for authorization are completed, the worker is ‘authorized’ by the employer to carry out the task.
Supervision is one of the most critical of the Administrative Controls. Sound supervision can make all of the above work. Failure to properly supervise work can cause all of these measures to fail.

Failure Modes

Administrative controls have many failure modes. Here are some of the most common:

  • Failure to train;
  • Failure to inform workers regarding the hazards present and the related risks;
  • Failure to create and implement SOP’s;
  • Failure to provide and maintain special equipment needed to implement SOP’s;
  • No formal means of authorization – i.e. How do you KNOW that Joe has his lift truck license?;
  • Failure to supervise adequately.

I’m sure you can think of MANY other ways that Administrative Controls can go wrong!

5. Personal Protective Equipment (PPE)

PPE includes everything from safety glasses, to hardhats and bump caps, to fire-retardant clothing, hearing defenders, and work boots. Some standards even include warning devices that are worn by the user, such as gas detectors and person-down detectors, in this group.
PPE is probably the single most over-used and least understood risk control measure. It falls at the bottom of the hierarchy for a number of reasons:

  1. It is a measure of last resort;
  2. It permits the hazard to come as close to the person as their clothing;
  3. It is often incorrectly specified;
  4. It is often poorly fitted;
  5. It is often poorly maintained; and
  6. It is often improperly used.

The problems with PPE are hard to deal with. You cannot glue or screw a set of safety glasses to a person’s face, so ensuring the the protective equipment is used is a big problem that goes back to supervision.

Many small and medium sized enterprises do not have the expertise in the organization to properly specify, fit and maintain the equipment.

User comfort is extremely important. Uncomfortable equipment won’t be used for long.

Finally, by the time that properly specified, fitted and used equipment can do it’s job, the hazard is as close to the person as it can get. The probability of failure at this point is very high, which is what makes PPE a measure of last resort, complementary to the more effective measures that can be provided in the first three levels of the hierarchy.

If workers are not properly trained and adequately informed about the hazards they face and the reasons behind the use of PPE, they are deprived of the opportunity to make safe choices, even if that choice is to refuse the work.

Failure Modes

Failure modes for PPE include:

  • Incorrect specification (not suitable for the hazard);
  • Incorrect fit (allows hazard to bypass PPE);
  • Poor maintenance (prevents or restricts vision or movement, increasing the risk; causes PPE failure under stress or allows hazard to bypass PPE);
  • Incorrect usage (failure to train and inform users, incorrect selection or specification of PPE).

Time to Apply the Hierarchy

So now you know something about the ‘hierarchy of controls’. Each layer has its own intricacies and nuances that can only be learned by training and experience. With a documented risk assessment in hand, you can begin to apply the hierarchy to control the risks. Don’t forget to iterate the assessment post-control to document the degree of risk reduction achieved. You may create new hazards when control measures are applied, and you may need to add additional control measures to achieve effective risk reduction.

The documents referenced below should give you a good start in understanding some of these challenges.

References

5% Discount on All Standards with code: CC2011

NOTE: [1], [2], and[3]  were combined by ISO and republished as ISO 12100:2010. This standard has no technical changes from the preceding standards, but combines them in a single document. ISO/TR 14121-2 remains current and should be used with the current edition of ISO 12100.

[1]             Safety of machinery – Basic concepts, general principles for design – Part 1: Basic terminology and methodology, ISO Standard 12100-1, 2003.
[2]            Safety of machinery – Basic concepts, general principles for design – Basic terminology and methodology, Part 2: Technical principles, ISO Standard 12100-2, 2003.
[3]            Safety of Machinery – Risk Assessment – Part 1: Principles, ISO Standard 14121-1, 2007.
[4]            Safety of machinery — Prevention of unexpected start-up, ISO 14118, 2000
[5]            Control of hazardous energy – Lockout and other methods, CSA Z460, 2005
[6]            Fluid power systems and components – Graphic symbols and circuit diagrams – Part 1: Graphic symbols for conventional use and data-processing applications, ISO Standard 1219-1, 2006
[7]            Pneumatic fluid power — General rules and safety requirements for systems and their components, ISO Standard 4414, 1998
[8]            American National Standard for Industrial Robots and Robot Systems — Safety Requirements, ANSI/RIA R15.06, 1999.
[9]            Safety of machinery — Safety-related parts of control systems — Part 1: General principles for design, ISO Standard 13849-1, 2006
[10]          Safety of machinery – Functional safety of safety-related electrical, electronic and programmable electronic control systems, IEC Standard 62061, 2005
[11]           Functional safety of electrical/electronic/programmable electronic safety-related systems, IEC Standard 61508-X, seven parts.
[12]          Preparation of Instructions — Structuring, Content and Presentation, IEC Standard 62079, 2001
[13]          American National Standard For Product Safety Information in Product Manuals, Instructions, and Other Collateral Materials, ANSI Standard Z535.6, 2010.
[14]          Control of Hazardous Energy Lockout/Tagout and Alternative Methods, ANSI Standard Z244.1, 2003.
[15]          Safety of Machinery — Interlocking devices associated with guards — principles for design and selection, EN 1088+A1:2008.
[16]          Safety of Machinery — Guards – General requirements for the design and construction of fixed and movable guards, EN 953+A1:2009.
[17]          Safety of machinery — Guards — General requirements for the design and construction of fixed and movable guards, ISO 14120.
[18]         Safety of machinery — Safety distances to prevent hazard zones being reached by upper and lower limbs, ISO 13857:2008.
[19]         Safety of machinery — Positioning of safeguards with respect to the approach speeds of parts of the human body, ISO 13855:2010.

5% Discount on All Standards with code: CC2011

Using E-Stops in Lockout Procedures

This entry is part 6 of 11 in the series Emergency Stop

Emergency stop devices are sometimes, incorrectly, used as part of a lockout procedure for machinery. Learn more about how to correctly used these devices as part of Hazardous Energy Control Procedures for industrial machinery.

This entry is part 6 of 11 in the series Emergency Stop

Disconnect Switch with Lock and TagControl of hazardous energy is one of the key ways that maintenance and service workers are protected while maintaining industrial equipment. Not so long ago we only thought about ‘Lockout’ or ‘Lockout/Tagout’ procedures, but there is much more to protecting these workers than ‘just’ locking out energy sources. Inevitably conditions come up where safeguards may need to be removed or temporarily bypassed in order to diagnose problems or to make critical but infrequent adjustments to the equipment, and this is where Hazardous Energy Control Procedures, or HECP, come in.

One of the questions I often get when helping clients with developing HECPs for their equipment is, “Can we use the emergency stop circuit for lockout?”. As usual, there is a short answer and a long answer to that simple question!

The Short Answer

The short answer to this question is NO. Lockout requires that sources of hazardous energy be physically isolated or blocked. Control systems may be able to meet parts, but not all of this requirement. Read on if you’d like to know why.

The Long Answer

Lockout

Lockout procedures are now grouped with other adjustment, diagnostic and test procedures into what are called Hazardous Energy Control Procedures or HECP. In the USA, OSHA publishes a lockout standard in 29 CFR 1910.147, and ANSI publishes ANSI Z244.1.

Download ANSI standards

In Canada we didn’t have a standard for HECP until 2005 when CSA Z460 was published, although all the Provinces and Territories have some language in their legislation that at least alludes to the need for control of hazardous energy. In the Province of Ontario where I live, this requirement shows up in Ontario Regulation 851, Sections 42, 75 and 76.

In the EU, control of hazardous energy is dealt with in ISO 14118:2000, Safety of machinery — Prevention of unexpected start-up.

Download ISO Standards

If you have a look at the sections from the Ontario regulations, they don’t tell you how to perform lockout, and they make little mention of what to do with live work for troubleshooting purposes. The US OSHA regulations read more like a standard, but because they are in legislation they are prescriptive. You MUST meet this minimum requirement, and you may exceed it.

Let’s look at how lockout is defined in the standards.

Canada (Ontario) USA (OSHA) European Union

Lockout — placement of a lock or tag on an energy-isolating device in accordance with an established procedure, thereby indicating that the energy-isolating device is not to be operated until removal of the lock or tag in accordance with an established procedure.

CSA Z460, 2005

Lockout. The placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed.

Tagout. The placement of a tagout device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.

29 CFR 1910.147

2.14 lockout/tagout: The placement of a lock/tag on the energy isolating device in accordance with an established procedure, indicating that the energy isolating device shall not be operated until removal of the lock/tag in accordance with an established procedure. (The term “lockout/tagout” allows the use of a lockout device, a tagout device, or a combination of both.)

ANSI Z244.1-2003


3.3 isolation and energy dissipation

procedure which consists of all of the four following actions:

a) isolating (disconnecting, separating) the machine (or defined parts of the machine) from all power supplies;

b) locking (or otherwise securing), if necessary (for instance in large machines or in installations), all the isolating units in the “isolated” position;

c) dissipating or restraining [containing] any stored energy which may give rise to a hazard.

NOTE Energy considered in c) above may be stored in e.g.:

  • mechanical parts continuing to move through inertia;
  • mechanical parts liable to move by gravity;
  • capacitors, accumulators;
  • pressurized fluids;
  • springs.

d) verifying by using a safe working procedure that the actions taken according to a), b) and c) above have produced the desired effect.

ISO 14118-2000

As you can see, the definitions are fairly similar, although slightly different terms may be used. The ISO standard actually provides the best guidance overall in my opinion. Note that these excerpts are all taken from the definitions sections of the relevant documents.

One of the big differences between the US and Canada is the idea of ‘tagout’ (pronounced TAG-out for those not familiar with the term). Tagout is identical to lockout with the exception of the device that is attached to the energy isolating device. Under certain circumstances the US permits the use of a tag without a lock to secure the energy isolation device. This is not permitted in Canada under any circumstance, and the term ‘tagout’ is not officially recognized. In Canada the term is often taken to mean the addition of a tag to the locking device,  a mandatory part of the procedure.

Use of Controls for Energy Isolation

This is where the ‘rubber meets the road’ – how is the source of hazardous energy isolated effectively? To understand the requirements, let’s look at the definition for an Energy Isolating Device.

Canada USA EU

Energy-isolating device — a mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: a manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors; a line valve; a block; and other devices used to block or isolate energy (push-button selector switches and other control-type devices are not energy-isolating devices).

CSA Z460, 2005

Note – Bold added for emphasis – DN

Energy isolating device. A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: A manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors, and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy isolating devices.

Note – Bold added for emphasis – DN

Tagout device. A prominent warning device, such as a tag and a means of attachment, which can be securely fastened to an energy isolating device in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.

29 CFR 1910.147

2.8 energy isolating device: A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: a manually operated electrical circuit breaker, a disconnect switch, a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy.

2.20.1 tagout device: A prominent warning means such as a tag and a means of attachment, which can be securely fastened to an energy isolating device to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.

ANSI Z244.1-2003

4.1 Isolation and energy dissipation

Machines shall be provided with means intended for isolation and energy dissipation (see clause 5), especially with a view to major maintenance, work on power circuits and decommissioning in accordance with the essential safety requirement expressed in ISO/TR 12100-2:1992, annex A, 1.6.3.

Note – ISO/TR 12100-2 was withdrawn in Oct-10 and replaced by ISO 12100-2010. – DN Read more on this.

5.1 Devices for isolation from power supplies
5.1.1
Isolation devices shall:

  • ensure a reliable isolation (disconnection, separation);
  • have a reliable mechanical link between the manual control and the isolating element(s);
  • be equipped with clear and unambiguous identification of the state of the isolation device which corresponds to each position of its manual control (actuator).

NOTE 1 For electrical equipment, a supply disconnecting device complying with IEC 60204-1:1997, 5.3 “Supply disconnecting (isolating) device” meets this requirement.

NOTE 2 Plug and socket systems (for electrical supplies), or their pneumatic, hydraulic or mechanical equivalents, are examples of isolating devices with which it is possible to achieve a visible and reliable discontinuity in the power supply circuits.

For electrical plug/socket combinations, see IEC 60204-1:1997, 5.3.2 d).

NOTE 3 For hydraulic and pneumatic equipment, see also EN 982:1996, 5.1.6 and EN 983:1996, 5.1.6.

ISO 14118-2000


Brady 65675 Large Plug Lockout Device
BRADY Small Plug Lockout Device

As you can see from the above definitions, all the jurisdictions require that devices used for energy isolation are reliable, manually operable, mechanical devices. While electrical control systems that meet high levels of design reliability may meet the reliability requirements, they do not meet the requirements for physical, mechanical disconnection of the source of hazardous energy. Operator devices are specifically excluded from this use in Canada and the USA. Note that plug and socket combinations are permitted in all jurisdictions. Lockout devices such as Brady 65675 Large Plug Lockout Device like the Brady Small Plug Lockout Device shown here and similar devices can be used for this purpose. With some plugs it is possible to put a small lock through a hole in one of the contacts. In some jurisdictions, even the simple act of putting the plug in your back pocket while conducting the work is sufficient.

In addition, the energy isolation device is required to be able to be locked in the off, isolated, or blocked position. There are emergency stop button operators that can be purchased with an integrated lock cylinder, and there are some control operator accessories available that will allow control push buttons and selector switches to be locked in one position or another, but these do not meet the requirements of the above standards. They can be used in addition to an energy isolation device as part of the procedure, but not on their own as the sole means of preventing unexpected start-up.

BRADY Button Locking Device
BRADY Button Locking Device

Conclusions

Each machine or piece of equipment is required to have an HECP that is specific to that piece of equipment. ‘Global’ HECP’s are seldom useful except as a template document. Development of HECPs takes some careful thought and a thorough understanding of the kinds of work that will need to be done to maintain and service the machinery. Individual jurisdictions have some differences in the details of their regulations, but ultimately the requirements come down to the same thing: Protecting workers.

Control system devices such as stop buttons and emergency stop devices are not accepted as energy isolating devices and cannot be used for this purpose, although they may be used as part of the HECP shutdown procedure leading up to the physical isolation of the hazardous energy sources.

Excellent standards exist that cover development of these procedures and should be referenced as specific HECP are developed.

5% Discount on All Standards with code: CC2011

104602 – BRADY Button Locking Device
BRADY Button Locking Device

References

Canada

Ontario Regulation 851, Sections 42, 75 and 76.

CSA Z460-05 (R2010) – Control of hazardous energy — Lockout and other methods

USA

29 CFR 1910.147The control of hazardous energy (lockout/tagout).

ANSI Z244.1 – 2003 (R2008) – Control of Hazardous Energy – Lockout/Tagout and Alternative Methods

Download standards

Allen-Bradley 8579
Allen-Bradley 8579
International

ISO 14118 2000, Safety of machinery — Prevention of unexpected start-up

Download ISO Standards

Busting Emergency Stop Myths

This entry is part 3 of 11 in the series Emergency Stop

There are a number of myths that have grown up around emergency stops over the years. These myths can lead to injury or death, so it’s time for a little Myth Busting here on the MS101 blog!

This entry is part 3 of 11 in the series Emergency Stop

There are a number of myths that have grown up around emergency stops over the years. These myths can lead to injury or death, so it’s time for a little Myth Busting here on the MS101 blog!

What does ’emergency’ mean?

Consider for a moment the roots of the word ‘emergency’. This word comes from the word ‘emergent’, meaning a situation that is developing or emerging in the moment. Emergency stop systems are intended to help the user deal with potentially hazardous conditions that are emerging in the moment. These conditions have probably arisen because the designers of the machinery failed to consider all the foreseeable uses of the equipment, or because someone has chosen to misuse the equipment in a way that was not intended by the designers. The key function of an Emergency Stop system is to provide the user with a backup to the primary safeguards. These systems are referred to as “Complementary Protective Measures” and are intended to give the user a chance to “avert or limit harm” in a hazardous situation. With that in mind, let’s look at three myths I hear about regularly.

 

Myth #1 – The Emergency Stop Is A Safety Device

Waterwheel and belt. Credit: Harry Matthews & http://www.old-engine.com
A Fitz Water Wheel and Belt Drive, Credit: Harry Matthews & http://www.old-engine.com

Early in the Industrial Revolution machine builders realized that users of their machinery needed a way to quickly stop a machine when something went wrong. At that time, overhead line-shafts were driven by large central power sources like waterwheels, steam engines or large electric motors. Machinery was coupled to the central shafts with pulleys, clutches and belts which transmitted the power to the machinery.

See pictures of a line-shaft powered machine shop or click the image below.

Line Shaft in the Mt. Wilson Observatory Machine Shop
Photo: Larry Evans & www.oldengine.org

These central engines powered an entire factory, so they were much larger than an individual motor sized for a modern machine. In addition, they could not be easily stopped, since stopping the central power source would mean stopping the entire factory – not a welcome choice. Emergency stop devices were born in this environment.

Learn more about Line Shafts at Harry’s Old Engines.

See photos and video of a working line shaft machine shop. 

Due to their early use as a safety device, some have incorrectly considered emergency stop systems safeguarding devices. Modern standards make the difference very clear. The easiest way to understand the current meaning of the term “EMERGENCY STOP” is to begin by looking at the international standards published by IEC1 and ISO2.

emergency stop3
emergency stop function

function that is intended to

—   avert arising, or reduce existing, hazards to persons, damage to machinery or to work in progress,

—   be initiated by a single human action

NOTE 1

Hazards, for the purposes of this International Standard, are those which can arise from

—   functional irregularities (e.g. machinery malfunction, unacceptable properties of the material processed, human error),

—   normal operation.

It is important to understand that an emergency stop function is “initiated by a single human action”. This means that it is not automatic, and therefore cannot be considered to be a risk control measure for operators or bystanders. Emergency stop may provide the ability to avoid or reduce harm, by providing a means to stop the equipment once something has already gone wrong. Your next actions will usually be to call 911 and administer first aid.

Safeguarding systems act automatically to prevent a person from becoming involved with the hazard in the first place. This is a reduction in the probability of a hazardous situation arising, and may also involve a reduction in the severity of injury by controlling the hazard (i.e., slowing or stopping rotating machinery before it can be reached.) This constitutes a risk control measure and can be shown to reduce the risk of injury to an exposed person.

Emergency stop is reactive; safeguarding systems are proactive.

In Canada, CSA defines emergency stop as a ‘Complementary Protective Measure’ in CSA Z432-046:

6.2.2.1.1
Safeguards (guards, protective devices) shall be used to protect persons from the hazards that cannot reasonably be avoided or sufficiently limited by inherently safe design. Complementary protective measures involving additional equipment (e.g., emergency stop equipment) may have to be taken.

6.2.3.5.3 Complementary protective measures
Following the risk assessment, the measures in this clause either shall be applied to the machine or shall be dealt with in the information for use.
Protective measures that are neither inherently safe design measures, nor safeguarding (implementation of guards and/or protective devices), nor information for use may have to be implemented as required by the intended use and the reasonably foreseeable misuse of the machine. Such measures shall include, but not be limited to,

(a) emergency stop;
(b) means of rescue of trapped persons; and
(c) means of energy isolation and dissipation.

In the USA, three standards apply: ANSI B11,  ANSI B11.19-2003, and NFPA 79:

ANSI B11-2008

3.80 stop: Immediate or controlled cessation of machine motion or other hazardous situations. There are many terms used to describe the different kinds of stops, including user- or supplier-specific terms, the operation and function of which is determined by the individual design. Definitions of some of the more commonly used “stop” terminology include:

3.80.2 emergency stop: The stopping of a machine tool, manually initiated, for emergency purposes;

7.6 Emergency stop

Electrical, pneumatic and hydraulic emergency stops shall conform to requirements in the ANSI B11 machine-specific standard or NFPA 79.
Informative Note 1: An emergency stop is not a safeguarding device. See also, B11.19.
Informative Note 2: For additional information, see ISO 13850 and IEC 60204-1.

ANSI B11.19-2003

12.9 Stop and emergency stop devices

Stop and emergency stop devices are not safeguarding devices. They are complementary to the guards, safeguarding device, awareness barriers, signals and signs, safeguarding methods and safeguarding procedures in clauses 7 through 11.

Stop and emergency stop devices shall meet the requirements of ANSI / NFPA 79.

E12.9

Emergency stop devices include but are not limited to, buttons, rope-pulls, and cable-pulls.

A safeguarding device detects or prevents inadvertent access to a hazard, typically without overt action by the individual or others. Since an individual must actuate an emergency stop device to issue the stop command, usually in reaction to an event or hazardous situation, it neither detects nor prevents exposure to the hazard.

If an emergency stop device is to be interfaced into the control system, it should not reduce the level of performance of the safety function (see section 6.1 and Annex C).

NFPA 79 deals with the electrical functions of the emergency stop function which is not directly relevant to this article, so that is why I haven’t quoted directly from that document here.

As you can clearly see, the essential definitions of these devices in the US and Canada match very closely, although the US does not specifically use the term ‘complementary protective measures’.

Myth #2 – Cycle Stop And Emergency Stop Are Equivalent

Emergency stop systems act primarily by removing power from the prime movers in a machine, ensuring that power is removed and the equipment brought to a standstill as quickly as possible, regardless of the portion of the operating cycle that the machine is in. After an emergency stop, the machine is inoperable until the emergency stop system is reset. In some cases, emergency stopping the machine may damage the equipment due to the forces involved in halting the process quickly.

Cycle stop is a control system command function that is used to bring the machine cycle to a graceful stop at the end of the current cycle. The machine is still fully operable and may still be in automatic mode at the completion of this stop.

Again, referring to ANSI B11-2008:

3.80.1 controlled stop: The stopping of machine motion while retaining power to the machine actuators during the stopping process. Also referred to as Category 1 or 2 stop (see also NFPA 79: 2007, 9.2.2);

3.80.2 emergency stop: The stopping of a machine tool, manually initiated, for emergency purposes;

Myth #3 – Emergency Stop Systems Can Be Used For Energy Isolation

Disconnect Switch with Lock and TagFifteen to twenty years ago it was not uncommon to see emergency stop buttons fitted with locking devices.  The locking device allowed a person to prevent the resetting of the emergency stop device. This was done as part of a “lockout procedure”. Lockout is one aspect of hazardous energy control procedures (HECP).  HECPs recognize that live work needs to be done from time to time, and that normal safeguards may be bypassed or disconnected temporarily, to allow diagnostics and testing to be carried out. This process is detailed in two current standards, CSA Z460 and ANSI Z244.1. Note that these locking devices are still available for sale, and can be used as part of an HECP to prevent the emergency stop system or other controls from being reset until the machine is ready for testing. They cannot be used to isolate an energy source.

No current standard allows for the use of control devices such as push buttons or selector switches to be used as energy isolation devices.

CSA Z460-05 specifically prohibits this use in their definition of ‘energy isolation devices’:

Energy-isolating device — a mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: a manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors; a line valve; a block; and other devices used to block or isolate energy (push-button selector switches and other control-type devices are not energy-isolating devices).4

Similar requirements are found in ANSI Z244.15 and in ISO 138503.

Myth #4 – All Machines are Required to have an Emergency Stop

Some machine designers believe that all machines are required to have an emergency stop. This is simply not true. A reader pointed out to me that CSA Z432-04, clause 7.17.1.2, does make this requirement. To my knowledge this is the only general level (i.e., not machine specific) standard that makes this requirement. I stand corrected! Having said that, the rest of my comments on this topic still stand. Clause 7.17.1.2 limits the application of this requirement:

7.17.1.2

Each operator control station, including pendants, capable of initiating machine motion shall have a manually initiated emergency stop device.

Emergency stop systems may be useful where they can provide a back-up to other safeguarding systems. To understand where to use an emergency stop, a start-stop analysis must be carried out as part of the design process. This analysis will help the designer develop a clear understanding of the normal start and stop conditions for the machine. The analysis also needs to include failure modes for all of the stop functions. It is here that the emergency stop can be helpful. If removing power will cause the hazard to cease in a short time, or if the hazard can be quickly contained in some way, then emergency stop is a valid choice. If the hazard will remain for a considerable time following removal of power, then emergency stop will have no effect and is useless for avoiding or limiting harm.

For example, consider an oven. If the burner stop control failed, and assuming that the only hazard we are concerned with is the hot surfaces inside the oven, then using an emergency stop to turn the burners off only results in the start of the natural cooling cycle of the oven. In some cases that could take hours or days, so the emergency stop has no value. It might be useful for controlling other hazards, such as fire, that might be related to the same failure. Without a full analysis of the failure modes of the control system, a sound decision cannot be made.

Simple machines like drill presses and table saws are seldom fitted with emergency stop systems. These machines, which can be very dangerous, could definitely benefit from having an emergency stop. They are sometimes fitted with a disconnecting device with a red and yellow handle that can be used for ’emergency switching off’. This differs from emergency stop because the machine, and the hazard, will typically re-start immediately when the emergency switching off device is turned back on. This is not permitted with emergency stop, where resetting the emergency stop device only permits the restarting of the machine through other controls. Reset of the emergency stop device is not permitted to reapply power to the machine on its own.

These requirements are detailed in ISO 138503, CSA Z4326 and other standards.

Design Considerations

Emergency Stop is a control that is often designed in with little thought and used for a variety of things that it was never intended to be used to accomplish. The three myths discussed in this article are the tip of the iceberg.

Consider these questions when thinking about the design and use of emergency stop systems:

  1. Have all the intended uses and foreseeable misuses of the equipment been considered?
  2. What do I expect the emergency stop system to do for the user of the machine? (The answer to this should be in the risk assessment.)
  3. How much risk reduction am I expecting to achieve with the emergency stop?
  4. How reliable does the emergency stop system need to be?
  5. Am I expecting the emergency stop to be used for other purposes, like ‘Power Off’, energy isolation, or regular stopping of the machine? (The answer to this should be ‘NO’.)

Taking the time to assess the design requirements before designing the system can help ensure that the machine controls are designed to provide the functionality that the user needs, and the risk reduction that is required. The answers lie in the five questions above.

Have any of these myths affected you?

Got any more myths about e-stops you’d like to share?

I really appreciate hearing from my readers! Leave a comment or email it to us and we’ll consider adding it to this article, with credit of course!

References

5% Discount on All Standards with code: CC2011

  1. IEC – International Electrotechnical Commission. Download IEC standards, International Electrotechnical Commission standards.
  2. ISO – International Organization for Standardization Download ISO Standards
  3. Safety of machinery — Emergency stop — Principles for design, ISO 13850, 2006, ISO, Geneva, Switzerland.
  4. Control of Hazardous Energy ­– Lockout and Other Methods, CSA Z460, 2005, Canadian Standards Association, Toronto, Canada.
    Buy CSA Standards online at CSA.ca
  5. Safeguarding of Machinery, CSA Z432-04, Canadian Standards Association, Toronto, Canada.
  6. Control of Hazardous Energy – Lockout/Tagout and Alternative Methods, ANSI/ASSE Z244.1, 2003, American National Standards Institute / American Society of Safety Engineers, Des Plaines, IL, USA.
    Download ANSI standards
  7. American National Standard for Machine Tools – Performance Criteria for Safeguarding, ANSI B11.19-2003, American National Standards Institute, Des Plaines, IL, USA.
  8. General Safety Requirements Common to ANSI B11 Machines, ANSI B11-2008, American National Standards Institute, Des Plaines, IL, USA.
  9. Electrical Standard for Industrial Machinery, NFPA 79-2007, NFPA, 1 Batterymarch Park, Quincy, MA 02169-7471, USA.
    Buy NFPA Standards online.

5% Discount on All Standards with code: CC2011

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