Recently I read a blog post written by David Cant, called, “Are You Making These Risk Assessment Blunders?“. Writing in the UK, Mr. Cant spoke to some of the common kinds of problems that can occur when employers conduct risk assessments. Many his points are equally applicable to machine building:
- No Risk Assessment – This seems self evident, since you can’t work to control what you don’t know exists. Unfortunately, some liability lawyers have advised clients NOT to conduct risk assessments, on the basis that you can’t be blamed for something you knew nothing about. This position is changing, since risk assessment has become a fundamental piece of the machinery design process and is included in US, Canadian, International, EU, and Australian standards to name a few. What remains as a liability are poorly done risk assessments, and those can certainly hurt a company in a liability case. See Point 3.
- Not Properly Identifying Hazards – This is another big one. Machine builders sometimes fail to understand the hazards that are incorporated into their machinery, especially in the case of system integrators. Identification is the first step, analysis is the second step. Once the hazard has been identified, the assessors must analyze the hazard to understand the magnitude of injury that can occur, e.g., a paper cut, hearing loss, permanent musculoskeletal disorder, fatality, etc.
- Creating an inadequate risk assessment – If you “phone it in”, any knowledgable person will be able to see that, and you can be sure that prosecutors will bring that to the attention of the court! Any claim that is made will be refuted by a knowledgable person hired by the prosecution.
- Assuming Safety Because You Have a Document – A risk assessment report never protected anyone from harm. Actions based on the report are what protect people from harm. Simply completing a risk assessment and sticking the report in the design file fixes nothing, and going back to the liability discussion, will create problems when it becomes clear that a) You knew about the risks, b) You thought out mitigation measures for the risks, but c) You failed to act on your own recommendations.
- Not involving your employees – I would change this to read, “Not involving the customer or end user.” Getting a risk assessment done by an outside individual is likely going to result in a poor outcome, if that person does not work with the knowledgable people in your organization. If this is an internal risk assessment for a process used in-house, then you need the workers involved with the process to be part of the risk assessment team. You also need the process designers (electrical, mechanical, software, etc.). If this is a product development risk assessment, then you will need product designers, marketing or sales people, and end-users. In all cases you may also need outside experts to help with hazard analysis and mitigation, since you may not have the expertise in-house. A good example of this is the use of industrial lasers into processes.
- Assessing risk generically – this goes back to point 3 – a risk assessment has to be relevant to the process, product or service that it describes. Using a risk assessment developed by someone else for some other similar product, process or service limits your thinking to just what they decided was relevant. Better to start with a blank sheet, and only at the end look at other’s work to see if you may have missed anything they included.
- Doing the risk assessment after the machine has been designed, built and put into use – This is a common problem, and especially affects workplaces that buy off-the-shelf machinery and used machinery. Many machine builders are not familiar with risk assessment or the benefits to their products, their liability exposure, and their reputation in the marketplace, let alone the benefits to their customers. Conducting the risk assessment after the equipment is in use means that the first stage of the Hierarchy of Controls cannot be used. Since this is the only stage that can achieve 100% risk reduction, this is a HUGE loss. In addition, this means that any changes needed to mitigate risk require expensive changes when the machinery is already in production, compounding the expense with lost production. If you have no other option — for instance, you’ve taken over an existing business and no risk assessments have been done in the past, then late is better than never, but it should be a last resort and not the first choice. Special thanks to Douglas Florence for suggesting this added blunder!
All of this brings me to some important standards. The Canadian Standards Association released CSA Z1002, Occupational health and safety – Hazard identification and elimination and risk assessment and control, in 2012. This is a landmark standard, because it addresses workplace risk assessment. No other standards development organization has released anything quite like it. There are some innovative ideas in the standard, including the idea of “risk transfer.” This concept explains how risk is transferred from the developer or supplier of a product, process or service, called the “external context”, to the user organization, called the “internal context”, and then to the worker. At each transfer point, the risk should have been reduced so that the worker’s exposure is as low as possible, and certainly no higher than permitted by law.
In the machinery world, the “mother standard” is ISO 12100, Safety of machinery — General principles for design — Risk assessment and risk reduction. This standard affects many of the machinery safety standards developed worldwide, including CSA Z432 and the ANSI B11 standards, and is harmonized under the Machinery Directive as EN ISO 12100. This standard lays out the process for safe machine design and provides the framework for machinery risk assessment. A companion document, ISO/TR 14121-2, Safety of machinery — Risk assessment — Part 2: Practical guidance and examples of methods, provides guidance on how to conduct a risk assessment, and offers up some example tools that could be used for this purpose. In the US, ANSI publishes ANSI B11-TR3, Risk Assessment and Risk Reduction – A Guide to Estimate, Evaluate and Reduce Risks Associated with Machine Tools, providing solar guides to users of the B11 family of standards.
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