Category Archives: Robotics - Page 2

Why you should stop using the term ‘Deadman’

Do you use the phrase ‘dead­man’ or ‘dead­man switch’ when talk­ing about safety related con­trols on your machin­ery? I often run into this when I’m work­ing with clients who use the terms to refer to ‘enabling devices’ — you know, those two or three-​​position switches that are found on robot teach­ing pen­dants and in other appli­ca­tions to give the oper­a­tor a way to stop machin­ery, even if they have already been injured or killed by the equip­ment. Calling these devices a ‘Deadman Switch’ or even a ‘Live-​​Man Switch’ as the three-​​position devices are some­times called, sends entirely the wrong mes­sage to the user as far as I’m con­cerned. The objec­tive of our work as machin­ery safety engi­neers is to pre­vent injuries from hap­pen­ing in the first place. Using a device that is designed to deter­mine if the user is dead or uncon­scious means some­one screwed up.

A lit­tle history

The term ‘dead­man’ comes from a device that was devel­oped by the rail­road loco­mo­tive builders in the 1800’s. In those days, loco­mo­tives were fired by coal or wood used to heat the boiler to gen­er­ate steam. The engines were usu­ally attended by two men: a Fireman and the Engineer. The Fireman’s job was pri­mar­ily to keep the fire­box stoked and to assist the Engineer. The Engineer’s job was to keep the loco­mo­tive run­ning, includ­ing dri­ving the train.

The cabin was gen­er­ally open at the back, and even in cold weather this was sel­dom a prob­lem because the heat from the fire­box was more than enough to keep the men warm. In the sum­mer, it was very dif­fi­cult to keep the cab cool enough, even with the win­dows open.

The motion of the engine was reg­u­lated with two valves, one that pro­vided the for­ward /​ reverse selec­tion and a long lever with a ratchet mech­a­nism that con­trolled the speed and brak­ing. The ratchet allowed the engi­neer to set the valve in one posi­tion and have it stay steady. As long as the boiler was pro­duc­ing suf­fi­cient steam, the engine would keep on rolling.

The loco­mo­tives occa­sion­ally had prob­lems with car­bon monox­ide build­ing up in the cab, caus­ing the engi­neer to slip into uncon­scious­ness and some­times die. As long as the CO didn’t also affect the fire­man, the engine could be stopped. In the sum­mer, the pos­si­bil­ity of heat exhaus­tion and heat stroke could also cause the men to suc­cumb while the train was moving.

A 'deadman' pedal in a locomotive.

A ‘dead­man’ pedal in a rail­way locomotive

Since the speed valve was nor­mally set in one posi­tion, the train could con­tinue with the crew uncon­scious or worse. After some ter­ri­ble acci­dents, design­ers came up with the ‘dead­man’ con­trol — the engi­neer would be required to main­tain a device in a cer­tain posi­tion in addi­tion to the speed con­trol valve, oth­er­wise the brakes would be applied stop­ping the engine. The intent was lit­er­ally to detect a dead man at the controls!

With the advent of elec­tric trains, trams and sub­ways, the con­cerns about heat and CO were elim­i­nated, but other pos­si­bil­i­ties, includ­ing heart attacks and other infir­mi­ties caused these devices to be inte­grated into these new trans­porta­tion sys­tems. To learn more about these appli­ca­tions, see the Wikipedia arti­cle Dead Man’s Switch.

It’s worth not­ing that the rail­ways now call these devices ‘Driver Safety Devices’ or DSD. See a mod­ern DSD at the Arrowvale Electronics web site.

Robots Enter the Picture

Robot Pendant showing Enabling Device

Motoman Pendant show­ing Enabling Device

In the 1980’s indus­trial robots began to appear in the work­place. Accidents in these early days drove changes in the design of the con­trol pen­dants used to ‘teach’ these devices their tasks. Early pen­dants pro­vided motion con­trol and an emer­gency stop device. Later, the motion con­trols were altered to become ‘hold-​​to-​​run’ devices that could jog the selected robot axis at a pre-​​selected slow-​​speed, one axis at a time. In the 90’s the ‘enabling device’ was added to the pen­dant. These two-​​position switches, still called ‘dead-​​man switches’, had to be held closed in order for the robot to move under con­trol of the axis hold-​​to-​​run con­trols. Accidents con­tin­ued to occur. In the mid 90’s the three-​​position enabling device, some­times called a ‘live-​​man-​​switch’, was intro­duced after stud­ies showed that some peo­ple would release their grip on the con­trol pen­dant when struck by the robot, while oth­ers would clench the hand hold­ing the pen­dant. The new switches are required to be held in the mid posi­tion to enable motion. The pic­ture at left shows the back of a mod­ern robot pen­dant. The black bar in the lower right is the enabling device, located so that your hand will nat­u­rally hold the device in the cor­rect posi­tion when you hold the pen­dant in your left hand. Not so good if you are left-​​handed!

ABB IRB640 Robot Pendant

ABB IRB640 Robot Pendant

 

 

Euchner ZS Switches

In addi­tion to the pen­dant enabling devices, addi­tional enabling devices are required where more than one worker is required inside the dan­ger zone of the machine. These devices can be pur­chased sep­a­rately and added to sys­tems as needed. Depending on the appli­ca­tion, you can get these devices with emer­gency stop but­tons and jog but­tons inte­grated into a sin­gle unit as shown in the pic­ture of the Euchner ZS switches.

Machinery Standards and Definitions

Enabling devices are one of those pro­tec­tive mea­sures that can­not be read­ily clas­si­fied as a safe­guard­ing device because they do not proac­tively pre­vent injury. INstead, like an emer­gency stop, they may allow a worker to avert or limit harm that is already occur­ing. That makes the enabling device a ‘com­ple­men­tary pro­tec­tive mea­sure’.

Let’s take a minute to look at a cou­ple of impor­tant def­i­n­i­tions from the machin­ery stan­dards. At the moment, the best def­i­n­i­tion for a com­ple­men­tary pro­tec­tive mea­sure comes from the Canadian stan­dard, CSA Z432-​​04. Excerpted from CSA Z432-​​04, §6.2.3.5.3 Complementary Protective Measures:

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.

Let’s also look at the for­mal def­i­n­i­tion of an ‘enabling device’ in the same standard:

7.23.3 Enabling devices
7.23.3.1
An enabling device is an addi­tional man­u­ally oper­ated 2– or 3-​​position con­trol device used in con­junc­tion with a start con­trol and which, when con­tin­u­ously actu­ated in one posi­tion only, allows a machine to func­tion. In any other posi­tion, motion is stopped or a start is prevented.

7.23.3.2
Enabling devices shall have the fol­low­ing features:

a) They shall be con­nected to a Category 0 or a Category 1 stop (see NFPA 79).

b) They shall be designed in accor­dance with ergonomic principles:

(i) posi­tion 1 is the off func­tion of the switch (actu­a­tor is not operated);

(ii) posi­tion 2 is the enabling func­tion (actu­a­tor is oper­ated); and

(iii) posi­tion 3 (if used) is the off func­tion of the switch (actu­a­tor is not oper­ated past its mid position).

c) Three-​​position enabling devices shall be designed to require man­ual oper­a­tion in order to reach posi­tion 3.

d) When return­ing from posi­tion 3 to posi­tion 2, the func­tion shall not be enabled.

e) An enabling device shall auto­mat­i­cally return to its off func­tion when its actu­a­tor is not man­u­ally held in the enabling position.

Note: Tests have shown that human reac­tion to an emer­gency may be to release an object or to hold on tighter, thus com­press­ing an enabling device. The ergonomic issues of sus­tained acti­va­tion should be con­sid­ered dur­ing design and instal­la­tion of the enabling device.

 

OMRON A4EG Enabling Switches

OMRON A4EG Enabling Switches

Similar def­i­n­i­tions exist in the International, European and US stan­dards, although they may not be quite as formalized.

 

Most enabling devices on their own do noth­ing except PERMIT motion to take place, although the actual def­i­n­i­tion of enabling device in CSA Z432 actu­ally per­mits the enabling device to cause motion. Absence of the enabling sig­nal pre­vents or stops motion. These devices are then used in con­junc­tion with hold-​​to-​​run con­trols on robots and machin­ery, and with throt­tle con­trols on trains, street cars, sub­ways and sim­i­lar equip­ment. Note that most stan­dards to not per­mit enabling devices to actu­ally cause motion. This is a unique sit­u­a­tion in the Canadian standard.

So what’s the big deal?

Using the terms ‘dead-​​man’ or ‘live-​​man’ to describe these devices puts the wrong mes­sage out as far as I’m con­cerned. As safety engi­neers and OHS prac­ti­tion­ers, we care about keep­ing work­ers out of dan­ger. This is nei­ther check­ing to see if we have either a ‘dead man’ or a ‘live man’, but rather ensur­ing that the per­son in con­trol of the equip­ment is ‘in con­trol’.  Using a phrase like ‘enabling device’ clearly says what the device does.

In my opin­ion, and  sup­ported by the cur­rent International and Canadian Standards, these terms must be aban­doned in favour of ‘enabling device’ and the qual­i­fiers ‘2-​​position enabling device’ and ‘3-​​position enabling device’. These terms are also used in many of the cur­rent machin­ery safety stan­dards, so using them cor­rectly improves clar­ity in writ­ing and speak­ing. Clarity in com­mu­ni­ca­tion in safety is too impor­tant for prac­ti­tion­ers to per­mit the ongo­ing use of terms that con­vey the wrong mes­sage and do not pro­mote clar­ity of mean­ing. Since clar­ity is often lack­ing when it comes to safety, any­thing we can do to improve our com­mu­ni­ca­tions should be high on our pri­or­ity list!

Updates to Popular Articles

This entry is part 8 of 9 in the series Emergency Stop

We’ve recently updated a cou­ple of our pop­u­lar arti­cles! Check them out!

Busting Emergency Stop Myths

Reader Question: Multiple E-​​Stops and Resets

Understanding the Hierarchy of Controls

Effectiveness of 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

*HMIHuman-​​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

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[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.

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