Operations verses Maintenace safety concerns

[gusto34]

What is the reqponsiblity of an equipment designer to protect a maintenance worker from lack of skill or training?Is there any sort of "official" analysis to distinguish operations from maintenance? My general concern is about the safety interlocks and other safety matters that may be inoperative during maintenance periods. A clear separation of Maintenance from Operations would help determine what qualifications and training are required for maintenance personnel who deliberately remove guards, bypass safety switches, etc. My immediate concern is about stored energy in a machine that cannot harm the normal operator, but is hazardous to a maintenance worker if he isn't properly trained.

Can anyone provide guidance on how to officially distinguish operations from maintenance, and also on what the design responsibilities would be?

 

[dwt]

In a nutshell, you need to do a safety review or hazard analysis for operation and a separate review/analysis for maintenance. After the review follow the safety heirarchy, first if possible design the hazard out, then consider guarding/interlocks, and warn of the dangers and provide instructions and training.

You may identify a hazard affecting the operator which may be guarded against but a lockout system may be required for the safety of the maintenance person. Review all the scenarios and possible hazards and design/warn/instruct accordingly.

 

[gusto34]

Thanks for the prompt replies. I understand the analysis steps to devise my own interpretation of operations and safety. But what I am seeking here is some form of "official" analysis procedure based on a regulatory or statuatory code, or an industry standard. My own interpretation may be adequate for routine operations when everyone is following the rules. However, when lawyers are involved, it helps to point to an accepted procedure and show that it was followed.

Thanks.

 

[conduit]

As a designer your job is to make things "idiot proof".
The lockout/tagout regulation in OSHA should give you a clue as to where a repairman's job end and where an operations work begins. Operations in the classical sense
is using the equipment as it was intended to be used ( with
guards installed securely) The Maintenance man job is to fix it ( removal of guards is necessary to fix it. However,
the key here is that they must lockout/tagout before doing this. If the operation requires troubleshooting, like adjustments. This is usually performed by either a setup man
or an operator depending on how involved it is. The reason for this is how the cost system is setup. Direct labor cost are associated with making the product.Fixing or adjusting which is what maintenance and setup people do is normally
considered indirect labor cost and is captured in the overhead. It is very important to keep track of labor hours
expend in these three operations (operator, maintenance and
setup. This labor charges need to be kept separate so that the Operations Manager can get a clear picture of operations. This information is also used for determining manpower requirements in the three functions.

As a designer, the less adjustment points and need for an employee to "touch the product" or P.M. the equipment the
better. ( make it idiot proof)

 

[gusto34]

I agree with all that has been written here, but we're still not quite onto my point. I suppose all of us here have a gut feel for when operations would stop and maintenance would start for any particular machine. There is always some grey area, where an operator does some minor maintenance during operation, but such procedures are usually protected by an e-stop, temporary lockout, etc. My concern is that after an e-stop or lockout-tagout has occured, and maintenance (as you and I easily understand it) is occuring, what protection for the maintenance worker is "mandated" by a code or standard.
I am hoping to locate an accepted guideline that determines what constitutes operations, and what constitutes maintenance, so that a specific set of worker skills and taining can be identified for each group. If an operator steps over the line into maintenance, then it's reasonable for him to be qualified enough to know all the hazards. But without a clear line between operations and maintenance, an argument can be made that the machine wasn't safe because it allowed an injury to the "operator."
Perhaps no such code exists to identify elements of separation, and it's therefore up to the owners of each installation to determine when "maintenance" is occuring. This is the situation I am facing now, but the owner wants to transfer responsibility back to the manufacturer. The mfg clearly understands that maintenance was occuring when the operator removed guards, but no one else seems to see things as clearly. An e-stop had been applied, but the nature of the machine caused a hazardous condition that affected the operator. My goal now is to identify if work involved was operations or maintenance.
Thanks.

 

[dwt]

The following exerpt is directly out of OSHA 1910.147.

Normal production operations. The utilization of a machine or equipment to perform its intended production function.

Servicing and/or maintenance. Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.

It further goes on to state:

The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:

1910.147(c)(7)(i)(A)
Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.

1910.147(c)(7)(i)(B)
Each affected employee shall be instructed in the purpose and use of the energy control procedure.

1910.147(c)(7)(i)(C)
All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure, and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out.

Therefore it is your responsibility to ensure that adequate guards and lockouts are designed into the machine and that proper instructions are provided. It then falls to the employer to ensure that the guards/lockouts are used and that the employees receive and understand the instructions.

The lawyers may scrutinize your selection of guards and lockouts and attempt to show that they were inadequate. Compare your guards/lockouts to your competitors and other similar machines for "state of the art" at the time the machine was manufactured.

Good Luck

 

[gusto34]

Thanks for the great response. Your OSHA citations are just what I was looking for.

Arthur Z.