Ask An Expert – Safety
As engineers design systems and products, user safety is on the forefront of every design decision. Products and systems must not injure the user when the product or system is used as intended, and often even as the product or system is used beyond the scope of the engineers’ initial intentions. Because of this, engineers must consider a variety of use cases that could potentially hurt an employee or end user. These considerations extend from heavy machinery and occupational hazards to consumer products.
To provide a roadmap in protecting workers, the National Institute for Occupational Safety and Health (NIOSH) uses a system called the Hierarchy of Controls to categorize strategies for mitigating hazards (Figure 1). This system ranks the ability to control exposures to occupational hazards from most effective to the least effective. Ideally, once a hazard has been identified it should be either eliminated or substituted.
Elimination and Substitution
Engineers should first attempt to eliminate or substitute any identified workplace hazard. Elimination requires the removal of certain features if they are deemed too hazardous and if the task can be accomplished within their absence. Substitution requires a technologically and economically feasible alternative. For each case, ARCCA Experts do a thorough search for alternative processes and designs and identify any relevant patents, to determine the existence of feasible alternative. However, elimination and substitution are considered to be the most difficult to implement without significantly impacting the existing process. Because of this, these steps are not always feasible without significantly impacting the design and occupational controls must be implemented.
If the hazard cannot be eliminated or substituted, the next most effective strategies are Engineering Controls. Engineering controls physically separate personnel from the hazards. The experts at ARCCA consider multiple federal standards, specifically the standards outlined in the United States Code of Federal Regulations (CFR) Title 29, such as OSHA 29 CFR 1910.212 in relation to machine guarding, and by the American National Standards Institute (ANSI) such as ANZI Z535.4-2011 for product safety signs and labels. A deep understanding of these standards and how they apply, allows the experts at ARCCA to effectively determine what was supposed to happen verses what actually happened when considering workplace injuries.
If the hazard cannot be removed, altered or designed against, the next acceptable method is to apply administration controls. Administrative controls provide rules on the way the work is done through internal policies and regulations. These actions include operating procedures, equipment maintenance and regularly scheduled trainings. A common practice to prevent occupational hazards are strictly defined rules for Lockout/Tagout procedures OSHA 29 CFR 1910.147. Properly followed procedures train employees to deenergize dangerous equipment before personnel are allowed to enter, effectively eliminating the hazardous environment.
Personal Protective Equipment (PPE)
Finally, the least effective, yet sometimes unavoidable, approach requires the use of Personal Protective Equipment (PPE). While not the ideal solution, the use of PPE allows individuals to complete required tasks when no other means of protection from hazards are available. ARCCA experts are well versed in OSHA 29 CFR 1910.132 and a wide array of ANSI standards and how they relate to the application, design and proper use of PPE. ARCCA experts are also very familiar with the process of walking through the hierarchy of controls to identify if the proper procedure was followed. This includes considering the design decisions of the engineers and the administrative actions of the company.
The hierarchy of controls is analogous to the considerations for user safety in consumer product design. The United States Consumer Product and Safety Commission provides a list of best practices when designing products for safety. Again, they begin by identifying any and all safety hazards and first seeking to reduce or eliminate the risk. If it is infeasible to eliminate the risk, the engineer must attempt to guard against the risk. If the risk cannot be eliminated or guarded against, the final option for the engineer is to warn and properly train the user. Depending on the complexity of product operation, trainings can consist of simple instructions all the way to specialized certifications and licensing requirements.
When ARCCA experts analyze a product failure that led to user injury, they first attempt to determine if the risk could have been avoided. We follow a similar process as with workplace hazards, by reviewing comparable products and current patents to determine if a technological and economical solution exists. Next we determine if the risk could be guarded against, specifically considering CFR Title 16 and a multitude of standards from various governing bodies such as American Society for Testing and Materials (ASTM) and Society of Automotive Engineers (SAE). Finally, we consider if applicable and adequate warnings and training were provided to the user to reduce the possibility of injury. We evaluate specific certifications and licensing requirements to ensure users were properly prepared to use the product. ARCCA experts can determine which standard relates to each scenario and if the standard was sufficiently applied.
Talk to a Safety Expert
Injuries are an unfortunate occurrence and while they can be reduced with strict adherence to safety guidelines and regulations, they will never be completed avoided. ARCCA experts are able to sift through the voluminous amount of industry standards and analyze complex system designs to determine the root cause of workplace injuries and product failures.