Why do we habitually start with a blank piece of paper when considering a machinery safety issue? JOE BAIN says we should stop reinventing the wheel and make use of readily available EU Type C standards.
So many of WorkSafe’s prosecutions are related to machinery that we as a country must be doing something wrong. Across the economy, we expend a significant amount of effort on machinery safety, but still have such high rates of harm that we can’t be getting value for that effort. I shudder to think how much money is spent each year on machinery safety – but the harm still occurs, so plenty of that money is wasted.
My own practice gives me an unusual perspective on this, and I have some ideas about the disconnect between effort and results. I do a lot of work for clients who want their machinery to be as safe as possible, but who have not had any accidents. I see those clients working hard to anticipate what could go wrong, worrying about increasingly unlikely scenarios, and plagued by fear that they might have missed something. They’re not all like that – there are plenty of clients who just want an improvement notice to go away – but by and large PCBUs want to do right.
Causes are foreseeable
I also do expert witness work after harm has occurred, when we have the benefit of hindsight and can figure out root causes and identify problems that contributed to the event. This is where I see the disconnect. In almost eight years of expert witness work I have yet to see a machinery-related incident where the cause wasn’t foreseeable – and already known. Not necessarily known to the PCBU, but known in a general sense because the event had occurred before. If only the right information had been available, to the right person, at the right time, harm could have been avoided.
This is where I think we are going wrong – we habitually treat every machinery safety question as if we must start from a blank piece of paper. As if we must start from first principles, identify all hazards, do all the risk assessment, then apply a hierarchy of controls and the machinery safety standard AS/NZS 4024 to come up with a suite of guards and safety features to protect people.
Recipe for disaster
That’s a recipe for the long, slow, unfolding disaster that is New Zealand’s machinery safety performance. We’re all busy people. We know that if you’re already overloaded, any task on the to-do list that encounters an obstacle, however small, is easy to put off. And a blank piece of paper isn’t just a small obstacle – it’s the most significant obstacle anyone can face.
Combine the blank piece of paper with the fact that most people aren’t machinery safety specialists, and we have a recipe for a lot of effort to be expended for very little result. On top of which, starting with raw hazard-id means that everyone’s decisions about what to do are anchored in what they have been doing. Without any external idea of what good should look like, we’re at the mercy of the seven most dangerous words in health and safety: ‘But we’ve always done it that way.’
Casting a wider net
Fundamentally, our approach to machinery safety relies too much on the experience only of the people who are involved in any specific question. Even when we do cast a wider net – looking to benefit from the experience of others – we tend to look at similar companies in our own region, occasionally look at experience in other regions, and that’s about it.
We tend not to look for experience in other industries that can translate into ours, and we tend not to look too far afield for lessons learned. We make the unconscious assumption that our circumstances are special, to fixate on ways in which our circumstances are special, and to lose sight of the ways our situation has been experienced before. I hate to use the word parochial, but we do tend to assume that every challenge is a bit different.
That’s a little bit silly – New Zealand doesn’t have its own special physics; machinery safety is the same here as it is everywhere people use machinery.
Look to Europe
Our tendency to waste effort reinventing the wheel is reflected in the guidance we have available for machinery safety. When it was decided that AS/NZS 4024 needed to exist, at least Australia and New Zealand didn’t start from a blank piece of paper – but we did fall into our other common trap, of only doing half the job, and leaving out the useful bit.
When we wanted a machinery safety standard, we went to the EU and set about licensing content. Europe has three tiers of machinery standards. The first two are Type A standards, which define the machinery safety approach, and Type B standards, which set out specific requirements for all the elements of a machinery safety system – light curtains, interlocks, and so on. We copied both the Type A and Type B standards, making them Parts One and Two of AS/NZS 4024. Later, Worksafe put together the Best Practice Guide for Safe Use of Machinery, which is a simplified distillation of AS/NZS 4024. All fine as far as it goes, but all requiring PCBUs to start from a blank piece of paper.
However, the EU also has Type C standards. These are basically model answers for specific machines. It’s not a universal rule, but in principle a robust application of the Type A and B standards to a particular machine type should lead to a safety system very like what’s documented in the Type C standard. The difference is, all the work has been done, so all you must do is apply the Type C standard. It might not be perfect, and it might need some risk-based modification one way or the other – but it will be a lot better and a lot easier than starting from scratch.
There are some Type C standards incorporated into 4024, but Europe has hundreds more that we never use. As a result, we waste vast amounts of effort reinventing the wheel – and sometimes the wheels we come up with are square.
Shoulders of giants
I contend that we should make use of humanity’s hard-won experience with machinery safety. We should stand on the shoulders of giants, and we should use the current state of knowledge as our baseline, rather than starting again all the time.
For example, say you were a manufacturer of log splitters. You could find yourself a risk assessment table template and start doing your own hazard-id – how many meetings have you sat in where a group of people blunder around trying to think of what the hazards are? – then decide on controls, and just hope for the best. That could take hours and hours of staff time, add safety features to your splitter that might or might not justify any additional expense, and at the end of it all you might not have made much difference.
Or you could look up a standard called EN 609-1 – Agricultural and Forestry Machinery – Safety of Log Splitters – Part 1: Wedge Splitters. It tells you exactly what to do. It sets out the safety features and control configuration. It even has pictures. Wood here is the same as wood there, people are basically the same, so the guidance would stand us in good stead.
And, if you bought it from the Estonian standards body, who sell all the EN standards in English, if would cost you €19.52, or about NZ$35 at the time of writing. You wouldn’t have to save much staff time to cover that cost, it would be easier, and the result would be better.
Doesn’t that just sound sensible?
Joe Bain, CPEng, is vice-Chair of the NZ Society for Engineering Safety and Operations Director of Motovated Design & Analysis. He presented on this topic at the Safeguard conference in June.
Safeguard
