Manufacturing AUTOMATION

Cracking the safety code

May 27, 2024
By Sukanya Ray Ghosh

Exploring the complexities of safety standards and compliance obligations for manufacturers in Canada.

PHOTO: ZOONAR RF / ZOONAR / GETTY IMAGES PLUS

Factory floors today are equipped with automated assembly lines, traditional and collaborative robots, automated mobile robots, high-voltage equipment, and more. For manufacturers, protecting against the risks and staying compliant with the most current safety standards will help keep workers safe and ensure fewer liabilities.

While the basic framework and intention behind machine safety standards are very similar everywhere, the specific standards vary according to region and even country. Canada has its own set of safety standards and regulations that manufacturers need to be aware of and compliant with, in order to minimize risks to workers and liabilities to their businesses.

Douglas Nix, co-owner of Compliance InSight Consulting, and a machine safety expert, shares that each province or territory has occupational health and safety (OHS) legislation governing the employer’s employee safety obligations. Federally, safety is governed by the Canada Labour Code, which covers workers employed in the federal sector.

Nix shares that every province and territory has its own legislation that governs electrical products that are connected to power supplied by a public utility. Equipment powered by the public utility is required to bear a recognized Canadian electrical safety mark. This can be a certification mark or a field evaluation label. Industrial equipment is also required to meet Industry Canada regulations for electromagnetic interference.

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“Machinery safety is handled differently depending on which province, territory or federal sector the employer is in. Canada, unlike the EU, for example, does not have legislation that requires manufacturers to build and sell safe products. They meet their legal obligations as long as the product has an electrical safety mark on it,” explains Nix.

However, he adds, Ontario enacted the Pre-Start Health and Safety Review (PSR or PSHSR). The employer is obligated through O Reg. 851 to conduct a PSR on the equipment. The PSR must be conducted by an Ontario-licenced Professional Engineer (P.Eng.). The result of the PSR is a report that either says the product complies with the requirements or it doesn’t. If it doesn’t, the report must include recommendations for modifications to bring the equipment into compliance.

Recent updates

Discussing the most recent updates to the standards, Nix shares that the general safety of machinery standard CSA Z432 was updated in 2023 and the lockout standard CSA Z460 was updated in 2020. CSA Z462, the workplace electrical safety standard, was updated in 2021.

“Staying current with the relevant standards in your industry is important. These standards, despite being voluntary, govern how machinery is built and used, including, in the case of Z460 and Z462, how maintenance work is done on these machines. If you don’t know the rules of the road, you can’t meet your legal obligations regarding protecting workers,” says Nix.

Nix notes that manufacturers must stay current with changes in the OHS legislation in the province or territory where they operate. If businesses have operations in more than one, they must stay current in all regions. The same principle applies to the standards.

“A manufacturer needs to know what standards are applicable in their industry and what they require. Machine builders and integrators need a standards library in their engineering office that holds current copies of the relevant standards so the designers can reference them as they develop product design. They also need to know what kinds of inspections and markings are required where the product will be sold. This can be a big job for companies selling products outside of Canada,” he says.

Common misconceptions and challenges

Machine safety standards are not discussed in any real depth in colleges and universities, shares Nix. Consequently, he says, new engineers usually learn about standards and applications while working with seniors.

“Learning to read standards is a challenge once you know that standards exist. Standards use certain keywords to indicate whether they are talking about a mandatory requirement by using the word “shall,” a strong recommendation when using the word “should,” or when they are permitting certain things when they are using the word “may.” The word “can” is also sometimes used when suggesting options,” explains Nix.

Nix shares that where the nuances of the specific language used are considered, the sense of a sentence or even a word as the standards committee sees it might not be what people may commonly understand.

“Many standards are written using performance-based language, which can be deliberately vague,” says Nix.

Understanding the nuances

Nix explains that international machinery standards fall into three types, defined in ISO 12100: Type A, B, and C. Type C standards apply to a specific type of machine, e.g., CNC turning centres, and are the most common. However, not every type of machine has an available type C standard. In such cases, manufacturers can fall back on the type A and B standards.

There is only one type A standard: ISO 12100. It defines the general process for the design of safe machinery. The type B standards are divided into type B1 and B2 standards. Type B1 standards cover particular safety aspects (for example, safety distances, surface temperature, or audible noise emissions). Type B2 standards cover safeguards (for example, two-hand controls, interlocking devices, pressure-sensitive devices, and guards).

“When designing a machine, the first step is to decide where the product will be sold. If you intend only to sell it in Canada, you likely only need to pay attention to CSA standards. If you’re also planning to sell in the U.S.A., then the ANSI standards should also be included in your research, and so on for other jurisdictions. Once you have that information, research to determine if a type C standard exists for the kind of machine you want to design. If there is one, buy it and follow it,” says Nix.

He adds, “If there isn’t a type C standard available, follow CSA Z432, or for the USA, ANSI B11.0, or ISO 12100 for international markets outside the EU. As you decide on various safety aspects, guided by the risk assessment, select the relevant type B1 and B2 standards. Follow those standards, ensuring the design meets every “shall” statement and documenting conformity at each step.”

Following these steps prepares manufacturers for conformity assessment.

The imperative to use standards

Purchasing and placing a standard on the shelf doesn’t add value. The document must be in the hands of the people making the design decisions. There need to be checks in the design process to ensure that the standard(s) are being used and that all requirements are being met. Once the enforcement is in place internally, use of the standard(s) will become second nature.

Failing to use the standards can come with significant downsides, says Nix. “In cases where injuries or fatalities have occurred, engineers doing forensic analyses will reference any relevant standards, not just the national standards. Every point of non-conformance will be identified and brought out in the forensic reports. In Ontario, a workplace fatality can result in a $250,000 company fine and a $25,000 personal fine for the supervisor(s) involved in managing the work. Other jurisdictions will have different limits.”

Nix adds that the Westray Act can be applied to cases where corporate negligence is found. This places such cases under the Criminal Code of Canada, section 217.1 [10]. Section 217.1 does not limit the size of the fines and prison sentences are possible for managers and supervisors, cautions Nix.


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