Manufacturing AUTOMATION: What is your biggest challenge as an MOL engineer?
Don Caskie: It seems to be guarding...Probably about 70 to 80 percent of my job would be assisting the inspectors in guarding. Obviously the manufacturers of equipment are not responsible under the [Occupational Health and Safety] Act for guarding of equipment, and when it comes to the end user, sometimes they don't realize that equipment that is sold in Canada doesn't have to be provided with guarding. So they use it from the manufacturer without any guarding at all. They think that the CSA sticker on equipment is proof that it meets all of the guarding standards, which unfortunately it doesn't. So we have to explain to certain employers, and generally smaller to medium-[sized] employers, that it's the end user that is required to comply with the legislation.
MA: Do you think the Act needs to be adjusted to include the manufacturers of equipment in it?
DC: I think that would be very difficult, because a lot of manufacturers are off-shore - China or the U.S. - and I don't know how the Act could make those suppliers responsible. The Act is based on the internal responsibility system, which puts all the responsibilities on the internal parties of the workplace - the employer, the worker, the supervisor, etc. The only time that manufacturers are liable under the Act is if they supply equipment under some kind of a leasing agreement, and they are responsible to make sure that the equipment that is supplied in that case does meet the regulations. Now one of the other things that is frequently omitted from the workplace is the requirement for pre-start reviews. Section 7 of our regulation requires that if equipment is installed in a workplace, and that equipment requires some kind of electronic device that signals a stop, for example a light curtain...or if you have an existing piece of equipment and you're installing that light curtain, then you need to have a pre-start review done by a professional engineer. Especially some of the smaller employers are really not aware of that requirement, and it comes as a bit of a shock to find that sometimes the cost of the PSR is actually more than the modification itself. In fact, I had a recent case where an employer installed an interlock on a gate, and when he was told that he had to have a PSR, he took the interlock off because he couldn't afford it. But there is an exemption to that - the requirement for a PSR. And it would help if the manufacturers provided the information to the employer to enable them to get by with the exemption. The exemption is that if the employer provides information that the equipment or the whole piece of equipment as a package unit, if that is provided with information stating that it is designed in accordance with the latest applicable standards, and it's installed in accordance with the manufacturer's instructions, as long as the employer keeps that information at hand, they don't need to do a pre-start review. So it saves them quite a bit of money...If the end user realizes that unless they have that information, they would need to do a PSR, I'm sure that requirement would be in a lot of purchasing contracts.
MA: What is the most common error in regards to machine safety that you see during inspections?DC: It's that, for example...if they put a guard over a piece of equipment, the guard isn't fixed in place. So the employer or the worker would just be able to take it off and stick his hand in the equipment. The other thing is not guarding the entire piece of equipment. They would guard the operator side, for example, of a press, and not look at the backside of a press. So somebody could go and put their hand in the backside of a press. But the question would be from the employer, 'Why would anybody do that?' So I think the biggest problem is that we as the Ministry of Labour, and the inspectors, and myself, see what could happen when somebody has had either a moment of inattention or has had a bad day at home, goes to work and does something which is completely out of character and normally would be regarded as stupid. The employer thinks, 'Well, okay, nobody would ever do that.' But they do. I've probably investigated over 40 fatalities and hundreds of critical injuries while I've been with the ministry, and probably the majority would be certain things that you wouldn't think that somebody would do. And that is what the legislation is trying to prevent. It is trying to prevent somebody from having a moment of inattention or negligence, going home without a hand or worse.