MACHINE SAFE GUARDING

SAFETY RULE #1

“All equipment is safe guarded, and

enables safe employee access”

Implementation Guidance

1 15-Jan-2019
1 – MACHINE SAFE GUARDING

All equipment is safe guarded, and enables safe

employee access

• All machinery is evaluated for prioritisation level,

with simple controls in place for all immediate and
Management severe risks
• All machinery has detailed risk assessments
completed on a prioritised basis
• Additional controls and improvement plans exist for
all known issues

• I always ensure that operators do not remove or by-

Supervisors pass existing safeguards
• I always complete safety pre-start checks on all
machines on my production lines

• I always follow the correct safe isolation method when

Employees I intervene with machinery

2 15-Jan-2019
CONTENTS
1 – MACHINE SAFE GUARDING ............................................................................................................... 2
CONTENTS ............................................................................................................................................... 3
BACKGROUND ......................................................................................................................................... 4
MANAGEMENT REQUIREMENTS ............................................................................................................ 5
1.1 All machinery is evaluated for prioritisation level, with simple controls in place for all
immediate and severe risks ....................................................................................................... 5
1.2 All machinery has detailed risk assessments completed on a prioritized basis ...................... 10
1.3 Additional controls and improvement plans exist for all known issues .................................. 12
SUPERVISORS REQUIREMENTS ............................................................................................................. 25
1.4 I always ensure that operators do not remove or by-pass existing safeguards ...................... 25
1.5 I always complete safety pre-start checks on all machines on my production lines............... 27
EMPLOYEES REQUIREMENT .................................................................................................................. 29
1.6 I always follow the correct safe isolation method when I intervene with machinery ............ 29

3 15-Jan-2019
BACKGROUND
RULE All equipment is safe guarded, and enables safe
employee access.
INTENT Every moving machine part, function, or process that can cause or potentially
cause injury must be safeguarded from physical contact. When the operation
of a machine or incidental contact can injure the operator or others in the
vicinity, the hazards must be eliminated or controlled.
HISTORY
Incidents have occurred both internally and externally resulting in significant injuries or
fatality. Inspections reveal guarding is sometimes removed and not replaced, leaving
exposed hazards

Multiple finger amputation

from inadequate guarding
on band saw

4 15-Jan-2019
MANAGEMENT REQUIREMENTS
1.1 All machinery is evaluated for prioritisation level,
with simple controls in place for all immediate and
severe risks
Safety Rules Audit
An external auditor will check for:
• A suitable prioritisation process is in place.
• Simple solution and short-term controls are in place.
• Top priority machines are included in the Capex plan.
Scoring Guide (3.1.1)
1 - No - Nothing has been done. No assessment or consideration of machinery hazards.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all machines on the zone plan are prioritised, or immediate and
severe risks have not been adequately addressed.
8 - Substantially implemented. All machines are evaluated for prioritisation level, and all immediate
and severe risks have simple controls in place to reduce risk.
10 - Yes - Substantially implemented and effective. All machines prioritised and updated when
changes occur, all immediate and sever risks have plans for effective engineered improvements.
Expectation
Prioritisation
To complete the detailed Risk Assessments, the machinery should be prioritised so that the
assessments are completed first on the machines that have the most significant issues.
Sites will develop a priority list of machinery that requires further detailed risk analysis by
actively looking for machine based hazards. This prioritization is designed to achieve two
points:
• Simple quick wins that can be resolved locally.
• Identify major pieces of equipment that require capex
The preferred method of prioritisation is using the KEF (Key Element Forms) template
‘_Template_MA_4._.xket’. This will allow comparison across all facilities and can be
conducted using internal or external personnel. The prioritisation is simple and can be
trained at local levels, via Zone ORMs.
It is advised that electrical experience is preferred due to the requirement to visually inspect
machine electrical panels. During this prioritisation stage, any immediate and severe issues
can be addressed quickly. The training includes examples of major issues.
If sites have recent and valid, existing reports, surveys or assessments, these should be
reviewed and can form the basis of the initial machinery prioritisation, if agreed with the
zone Certified Machinery Safety Expert (CMSE).

5 15-Jan-2019
Examples

Increasing safety

Simple prioritisation using the KEF method shows five Level 2 machines would be the first
priority for detailed assessments, followed by 22 Level 3 machines, and then the 29 Level 4
machines. The final Level 4 group, by definition, will have fewer issues that require the
detailed risk assessments.
Immediate and Severe Risk
The site will have as a minimum, basic safeguards in place to prevent accidental contact
with significant hazards associated with machinery. This point is aimed at sites where there
is no guarding and simple solutions can be implemented quickly, to reduce the risk.
A significant hazard is one that can cause a severe injury, resulting in permanent impairment
or disfigurement. In this situation, specifically from being struck by, or caught in, moving
machinery. The standard Machinery Assessment Process should identify these situations,
during the prioritization level, as ‘Immediate and Severe Risk’.
This rule applies in situations where there is no restricted access, and a person that slips or
trips while walking past the hazard has no opportunity to prevent contact if they fall. Simple
controls could include guarding, a grab rail, emergency stop pull cords, distance, or
restricted access.
Examples
The aim is to prevent situations like those below.

6 15-Jan-2019
Example 1
Below is a photo with some very old seamers, they have put a standard rail around the area
and have a procedure to lock out before entry through the gate.
Although this does not meet defined standards, it reduces risk and meets the requirement
to have simple controls in place, for example, to control accidental contact from slips trips
and controls pedestrian traffic.

Example 2
The operator stands on the platform on the left. In the bottom of the hopper on the right
there is a screw auger. It is possible the operator could easily slip and fall into the hopper.

7 15-Jan-2019
A simple immediate solution involved turning the platform around so the operator stands
behind the railing to prevent falling forward. Additional simple distance barrier was also
installed on the other side.

8 15-Jan-2019
Other Examples of moving machinery that would require safeguards.

9 15-Jan-2019
1.2 All machinery has detailed risk assessments
completed on a prioritized basis
Safety Rules Audit
An external auditor will check for:
• The site has been actively looking for machine hazards.
• A suitable assessment process is used and effective.
• Risk assessors are suitably trained.
• Outputs are actioned.
Scoring Guide (3.1.2)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all machines are prioritized and risk assessed, or assessments not
updated to reflect changes to machinery.
8 - Substantially implemented. All machines have detailed risk assessments completed.
10 - Yes - Substantially implemented and effective. All risk assessments completed, and effective
management of change with updated risk assessments for all machinery related changes.
Expectation
The detailed Risk Assessment is aimed at evaluating if the current condition of the machine
has adequate safeguards to protect employees.
The preferred method is to use onsite internal competent resource that meets the
competency guidance or equivalent below. It is preferred to use the KEF (Key Element
Forms) template ‘_Template_MA_4._.xket’. If there is an existing robust process, consult
with the zone Certified Machinery Safety Expert (CMSE) to determine the best method to
transfer the data to the preferred format.
If competent internal resource is not available, there is a Global Framework Agreement in
place with two preferred global providers, who can support with detailed assessment.
Contact ORM for details. Pre-CARs for the assessment can be included as part of the normal
AOP Capex process.
Methodology
ISO standards (International) are the preferred reference point, although others can be
used. ISO standards are international machine safety and quality standards, which define
hazards and controls for many machine types (‘C’ type standards) or specify details for
safeguard systems (‘B’ Type) that can be applied to all machines. This methodology is
aligned with ISO 12100 Safety of Machinery – Risk Assessment and Risk Reduction.

10 15-Jan-2019
Example ‘B’ Type standards
• ISO 13857 Safe reach distances
• ISO 13849 Safety control circuits
• ISO 14118 Prevention of unexpected start up
• ISO 4414 Safety of pneumatic systems
• These documents set out the safety requirements for safeguards that can be applied
to any machine or situation
Example ‘C’ Type standards
• EN 415 – 4 Safety of Palletisers and De-palletisers.
• EN 1678 Safety of vegetable cutting machines
• EN 1672 Food processing machines - Basic concepts for safety
• EN 13389 Mixers with horizontal shafts
• A long list is available.
• These documents detail all the significant hazards associated with several variations of
machine and also detail the controls required for these hazards.
If the situation meets the relevant ISO standard then it can be considered as safe. Where it
does not meet the ISO standard a Risk Assessment should be performed to determine the
level of risk. Generally, the further away from the ISO standard the higher the risk.
The level of risk can be quantified using the KHC Hazard Rating Number (KHRN)
KHRN = PO x DPH x FE x PA
PO = Possibility of Occurrence
DPH = Degree of Possible Harm
FE = Frequency of Exposure
PA = Possibility of Avoidance
For each parameter, a series of numbers are assigned to give a quantitative value of risk.
Further details on KHRN is available through training if the internal option is chosen.
Competence
The detailed Risk Assessment should be carried out, or at a minimum overseen, by a
qualified competent assessor. The CMSE (Certified Machinery Safety Expert) qualification is
an acceptable demonstration of competence. This qualification is run in conjunction with
Pilz and TUV. It is internationally recognised and Pilz have offices in all facility countries.
See http://www.cmse.com/en for more details.

11 15-Jan-2019
1.3 Additional controls and improvement plans exist
for all known issues
Safety Rules Audit
An external auditor will check for:
• Complete Risk Assessments with Improvements identified.
• Possible Residual Risk evaluations.
• Review improvement plans and capital projects.
• Inspections to confirm no significant machinery risks.
• Evidence that critical controls are adequately addressed.
Scoring Guide (3.1.3)
1 - No - Nothing has been done. No projects have been implemented to reduce risk.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all significant risks have controls implemented.
8 - Substantially implemented. Improvement plans and controls implemented to reduce risk to no
significant residual risk.
10 - Yes - Substantially implemented and effective. All assessments updated when changes occur,
and effective change control with no new significant risks introduced.
Expectation
When using the preferred Risk Assessment tool with the KEF (Key Element Forms) template
‘_Template_MA_4._.xket’, the detailed Risk Assessment identifies specific issues with each
machine and assesses a Risk Estimation and Evaluation. Risk Reduction / Improvements then
need to be identified and the Possible Residual Risk that would exist after implementation
assessed. The process is considered Substantially Implemented when the Risk Reduction /
Improvements have been implemented to the extent that there is no Significant Residual
Risk.
The following examples are critical controls that have been identified in our factories, and
can have a significant impact on risk. Site visits and audits will verify that these and other
significant risks have been addressed and adequately controlled.

12 15-Jan-2019
Machines have safeguards for non-operation modes (jog, setting, sanitation).
The site may be required to carry out specific tasks (i.e. setting, sanitation) on machines
with the guards open. This can only be carried out if other suitable safeguards are in place.
To determine if these situations are acceptable follow the flow chart in the reference
document 01_Reference_02 – Assessing Mode Selection and Hold To Run Functions for
each machine that can be run with the guards open.
Option One
The KEF (Key Element Forms) template’Alert_HTR_1.0’
can be used to record compliance.
Option Two
Record using local tools like Microsoft Excel.
Contact Regional ORM for support if required
An external auditor will look for:
• Evidence that these checks have been carried out.
• Inspect a sample of machines for compliance to the flow chart.
Examples

Homemade controller to move the

machine with the guards open

13 15-Jan-2019
All frequent access points to hazardous parts of machinery are interlocked.
The site should identify where frequent access to machinery is required and ensure suitable
interlocks are installed.
Prior to interlocks being engineered and installed, Lock Out procedures must be in place as a
short-term control.
Frequent access can be defined using the current industry standard which suggests
Frequent Access = Access more than 1 per week
External support may be required in designing and calculating safety circuits – for more
detail, refer to the reference document:
• 01_Reference_06 - Notes on Interlock Safety Circuits
An external auditor will check:
• A sample of machines to ensure frequently accessed hazardous areas are interlocked.
• A Performance Level for each new interlock circuit (safety function).
• How the installed circuit has been approved and validated (calculations provided).
• The site has used a competent person / company to design any safety circuits.
Examples

High frequency access point

interlocked and has ‘Guard
Locking’.
Access point is for changing
the plastic reel for the
pallet wrapper.

14 15-Jan-2019
Openings in guards/equipment must not allow access to hazards.
Guards are complete and do not have ‘holes’ or ‘gaps’ in them, where employees can access
hazardous parts. The tables in the reference document 01_Reference_03 – Safe Reach
Distances state specific dimensions that are considered ‘safe reach distances’. Machines
should be checked against these ‘safe distances’ when employees can reach over or through
guards.
An external auditor will check for:
• Suitable reach distances by auditing a sample of machines.
Examples

Gap in the guarding

allows full body
access into the
danger zone.
Maximum distance
= 180mm (see table
7 in ISO 13857)

Gap in the guarding

allows the operator
to reach in to the
danger zone.
Maximum distance
with 120mm gap in
guard = 850mm (see
table 3 in ISO 13857)
The operator should
use the interlocked
gate, shown in blue

15 15-Jan-2019
 Gap in the guarding
allows full body
access into the
machine.
Maximum size of
the opening
depends on the
distance to the
hazard (see tables)

Some operators try

to keep production
going by reaching
through guards.

16 15-Jan-2019
 No gaps it the guards, suitable
height with interlocked access
gates

No gaps it the guards, suitable

height with panels to contain
liquids

The spacing of the bars and

the distance from the hazard
should be reviewed against
the guidance. When
compliant, it should not be
possible to reach the hazard.
(In this example, the hand is
not touching the auger).

Some tables are reproduced in the guidance 01_Reference_03 – Safe Reach Distances
For the full standard (ISO 13857) and information on Safe Reach distance contact regional
ORM.

17 15-Jan-2019
Operators access large systems (palletisers or robotic cells) through designated
interlocked gates.
Operators should not access large systems through points that convey pallets or product, as
light guards can be reset if the operator cannot be seen.
Specific interlocked personnel gates should be provided.
Pallet entry / exit points will have safeguards (e.g. Light curtains) to prevent operators
gaining access to dangerous zones. Signage will also be displayed stating no access at these
locations.
An external auditor will check for:
• Audit a sample of machines to check if access is suitable and signage is in place at
large product entry and exit points.
Examples

Access for cleaning, under the

lift table on this palletiser is
only through the light curtain
and roller conveyor
It is better to clean without
going into this area, or access
through an interlocked
personnel gate

Access for cleaning, under

the lift table on this
palletiser is through an
interlocked access gate.

Palletiser Lift
Table inside
machine

18 15-Jan-2019
 Signage on interlocked
personnel access gate.
Safe Entry Procedure –
Insert ‘Pins’ to prevent the
lift table moving – SEE next
section below about
Restraining Energy.

Specific interlocked access

gate (with request to enter
control).

Pallet entry points.

Signage informing operators

that this is not a personnel
access point.

Light curtains only allow

pallet entry.

19 15-Jan-2019
 Signage.

Light curtains.

Signage.

Light curtains.

Multiple zones in a
perimeter fence with
several types of guarding
between the zones, e.g.
light guards, fixed fence
guarding

For designing safeguards for these types of systems further simple guidance can be found in
the following reference documents:
• 01_Reference_04 - Robot Cell - Safety Principles
• 01_Reference_05 - Robot Cell Good Practise Photographs
• EN ISO 11161:2007+A1:2010 Integrated Manufacturing Systems
• EN ISO 10218-2:2011 Robot Integration

20 15-Jan-2019
All machines are fitted with devices that remove or restrain energy.
Any stored energy in machines will have;
• A device to restrain (lock) the energy, or
• A device to remove the energy;
• Signage to inform employees that stored energy is present;
• Any devices that restrain stored energy are checked on a regular maintenance
routine.
Stored energy examples and devices are shown in examples below
An external auditor will check for
• Audit a sample of machines to check energy is removed / restrained.
• Signage is in place when stored energy is present.
• Maintenance records of restraining devices.
Examples
Stored Energy includes
1. Elevated loads (Energy stored due to the load being at height)
Machines, such as palletisers, may have a lifting table to lift the layer onto the pallet. This
lifting table should have a locking device when employees are working underneath
(cleaning, maintenance, etc.)

Restraint (Lock) System.

Palletiser Lift Table.

In this example the palletiser lift table is restrained / locked in position, by spring return
cylinders that push a piston into a recess when the employee enters through the interlocked
access gate.

21 15-Jan-2019
Close up photograph of the mechanism:

Restraint (Lock) System.

Palletiser Lift Table.

Other examples include

Pallet Wrapper
Carriage.

Pawl system to
restrain and lock the
load.

Pneumatically operated
pin, locks the head of a
large hydraulic ram when
it is fully raised.

Hydraulic ram.

22 15-Jan-2019
 Hydraulic lift palletiser.

Pin locations to
restrain / lock the
load.
Manual Pins.

Manual Pins are inserted

from outside the guards
before entering the
palletiser lift well.

Machines that may have stored energy from loads at height include
• Palletisers.
• Pallet Wrappers.
• Scissor Lift Tables.
• Hydraulic Presses.

2. Pneumatic circuits
Pneumatic circuits may retain pressure when opening an interlocked guard. Where possible
it should be identified how to remove any stored energy (pressure).
Where this is not possible suitable signage should be used to warn the employee that
pressure is still present.

23 15-Jan-2019
Machine reset can only be activated from outside the danger zone.
When resetting a machine after a safety stop (opening a guard / light curtain), the reset
button should only be accessible from outside the danger zone.
Anyone inside the danger zone should not be able to reach the reset point.
An external auditor will
• Audit a sample of machines to check if the reset locations can be reached from inside
the danger zones.
Examples
The aim is to prevent situations like these below.

Danger Zone

In this example, the reset control was moved to increase the reach distance.

The reset can also be a pull cord, commonly used when FLT drivers unload conveyors.

24 15-Jan-2019
SUPERVISORS REQUIREMENTS
1.4 I always ensure that operators do not remove or
by-pass existing safeguards
Safety Rules Audit
An external auditor will look for:
• Expectations have been communicated.
• A process is in place to risk assess any proposal for guard modification
• Inspect a sample of machines for guarding issues and the modification process
Scoring Guide (3.1.4)
1 - No - Nothing has been done, or evidence that by-passing guards is regular or common practice.
3 - Expectations communicated but some evidence of guards by-passed.
5 - Partially implemented. Management of Change not effectively implemented but no evidence of
guards by-passed.
8 - Substantially implemented. Communicated initially but needs updating. Management of Change
effective, and no guards by-passed.
10 - Yes - Substantially implemented and effective. Communicated annually, Management of Change
effective, and no guards by-passed.
Expectation
The site will have clear communications to all employees setting out the expectation that:
• Fixed guards must not be removed unless the machine is isolated and locked out.
• Guards must not be modified unless approved through Risk Assessment.
• Interlocks and guards must not be by-passed in any way.
Where guards need to be open for setting, maintenance or sanitation purposes, the
machine must comply with the requirement that all frequent access points to hazardous
parts of machinery are interlocked.

25 15-Jan-2019
Examples
The aim is to prevent situations like those below.

Interlocks by-passed Guard Removed to allow access for clearing

jammed pallets

Guard modified by cutting large hole for Washer taped over interlock sensor on
access. No change control. machine door.

26 15-Jan-2019
1.5 I always complete safety pre-start checks on all
machines on my production lines
Safety Rules Audit
An external auditor will check for evidence that:
• Pre-Start safety checks are in place
• Functional safety checks are in pace
Scoring Guide (3.1.5)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all machines have both pre-start visual inspections and functional
safety checks
8 - Substantially implemented. Pre-Start visual inspections on all machines, and functional safety
checks on critical components.
10 - Yes - Substantially implemented and effective. Pre-Start visual inspections and functional safety
checks are in place for all machines.
Expectation
All machines have a system in place to check safety systems are in place and functional.
Sites can follow the specific detail in reference document 01_Reference_01 - Pre-Start and
Functional Safety Checks.
Pre-start safety checks are usually defined by production line, with the area supervisor
responsible for their completion. The frequency of checks should be defined. For example,
some items may only need checking at the start of a production run or after sanitation, such
as the replacement of a fixed guard that was removed for cleaning. Other items should be
checked after a shift handover, such as the incoming supervisor completing a
housekeeping/5S inspection of the line.
Functional safety checks are required less frequently as explained in the reference
document above, and are usually the responsibility of a technical role. For example, testing
that electrical interlocks and emergency stops continue to function as designed and as
expected.

27 15-Jan-2019
Examples

28 15-Jan-2019
EMPLOYEES REQUIREMENT
1.6 I always follow the correct safe isolation method
when I intervene with machinery
Safety Rules Audit
An external auditor will:
• Check documented procedures for correct safe isolation methods.
• Check documentation of training and communications.
• Review use of the OSCAR board, and follow-up actions.
• Look for physical evidence of isolation controls.
• Interview employees through a conversation to understand current practices and
general level of understanding.
• Observe behaviour during factory inspections.
Scoring Guide (3.1.6)
1 - No - Nothing has been done.
3 - Implementation is at an early stage or there is a substantive lapse.
5 - Partially implemented. Not all the verification steps align, and substantial improvement is
required.
8 - Substantially implemented. Evidence from all the verification steps is aligned, and only minor
improvements are recommended.
10 - Yes - Substantially implemented and effective. Evidence from all the verification steps is aligned
and consistently maintained. No further improvements identified.
Expectation
The ‘correct safe isolation method’ will be specific to a given intervention task and machine
combination. For example, to unblock a jam and reset a machine, there may be an inter-
locked door that is designed to isolate power to the specific hazards the employee is ex-
posed to during that task, and the employee is in control of the isolation point the entire
time. For other tasks, a Lock Out procedure may be the correct method. Refer to the Lock
Out Guidance for more information.
Intervention is defined as interactions with a machine that are beyond normal operation,
especially accessing or touching parts of the machine beyond the normal operator panels
and controls. This most often occurs when troubleshooting, such as clearing blockages and
jams, but can also occur during set-up, adjustments, cleaning, sanitation and maintenance.
Where employees are expected to intervene with machinery, the correct safe isolation
method must be identified and documented for the specific task/machine combination. The
employees then need to know what the method is, with supervision to ensure it is followed.
This requirement is one of the basic employee OSCAR board checks for production, pro-
cessing, or packing lines, where machinery interventions occur. During initial implementa-
tion, it may be helpful to get employees to note the interventions on the OSCAR board, so
that the site ORM resource can review them for the correct isolation method.
During machinery design and installation, consideration should be given to making the cor-
rect safe isolation method the most convenient, which is the best way to ensure it is used
consistently.

29 15-Jan-2019