Element 8.9 Machine Guarding - Gap Analysis

Some machine guarding is in place.

Written program specifies: <br>• Roles and responsibilities; <br>• Machine survey and assessments (E8.9-2.2);<br>• Machine guarding methods;<br>• Safeguarding requirements;<br>• Inspection and control frequency; (7)<br>• Employee training requirements.<br><br>A revision log shall be included as part of the written program.

Survey is completed within 3 months of program introduction and work is prioritized based on risk present.

Machines requiring daily safeguard inspections have been identified and machine specific forms have been developed for the inspection.

Written program is reviewed annually and updated as necessary. The revision log has been maintained to reflect the annual review and any other changes made to the written program throughout the year.

Supervisors , maintenance and machine operators receive formalized training, including exams, upon assignment and every three years thereafter. <br>Effective refresher training is provided during other years.

Trainers are competent and qualified to train on the subject matter.

Site maintains a list of qualified employees (machine operators and maintenance) which includes the date of last formalized training.

New or modified equipment is assessed for machine guarding. Guarding is in place before machine is released to production.

Process exist to determine if guarding is being inspected when required (i.e. light curtains, open interlock doors)

Machine guarding is implemented in timely manner

Guarding is adequate to prevent employees from accessing points of hazard

Guarding is always in place before an operation is started.

Employee knows how to inspect guarding when required (e.g. light curtains, open interlock doors) and inspections are performed.

Documentation (e.g. machine stop times) is available to support the location (minimum distance) of light curtains, two-hand trips and similar devices relative to point of operation hazards. Measurements are made at the time of installation of safeguards and at least every three years thereafter to support the location of the safeguards. Stop times must be verified if there is reason to believe the condition of the machine has deteriorated and after any major repairs which could have effected the machine’s stop time.

Daily safeguarding inspection forms include pictures with arrows and other references which clearly show what must be inspected.

Employees (affected, authorized and other) understand their roles and responsibilities.