Facts You Should Know
About Machine Guarding Regulations
and Safety Light Curtains
Accidents are costly, not only in purely human terms, but also in lost
productivity, potential fines, lawsuits and damaging publicity. The lack of
adequate safeguards can also increase the cost of your workers compensation
insurance.
This booklet answers some important questions about machine guarding
regulations, and the effective use of safety light curtains.
What's the difference between OSHA and ANSI?
The Occupational Safety and Health Administration (OSHA) is the federal
agency responsible for writing and enforcing workplace safety regulations in
the U.S. OSHA performs inspections, issues citations, levies fines and
provides consulting services.
OSHA 1910.217 includes a specific regulation governing the use of
presence-sensing devices, such as safety light curtains, for mechanical power
press guarding. However, OSHA states that applicable industry standards (such
as ANSI) are to be followed in the absence of a specific OSHA regulation.
ANSI (the American National Standards Institute) is the national coordinating
body for voluntary standards activity. Its standards reflect a nationwide
consensus of industry professionals; consumers; scientific, technical, and
professional organizations; and government agencies. ANSI sets rules on how
standards should be formulated and balloted. If a standard is written to
these requirements, it is then adopted and published by ANSI.
Why is it mandatory to comply with OSHA regulations?
Regulations are in place to provide safety for everyone in the workplace. Steep fines (or criminal charges, in extreme
cases) may be imposed if these regulations are not followed.
On the positive side, adhering to the regulations helps protect your workers
from injury, and could reduce your workers compensation insurance costs.
Do I have to comply with ANSI standards?
ANSI standards are regarded as the industry's accepted minimum safety
standards. In the absence of a specific OSHA regulation, ANSI standards are
considered a legal requirement for all machines except mechanical power
presses. ANSI standards include ANSI/RIA15.06 "Industrial Robots and
Robot Systems," ANSIB11.19 "Performance Criteria for Safeguarding,
" and ANSIB11.20 "Manufacturing Systems/Cells." Besides
carrying significant weight in legal proceedings, these standards are also
referenced in OSHA citations.
Which OSHA standards apply to light curtains?
The standards include: OSHA1910.212 (General Requirements for All Machinery);
OSHA1910.217 (Mechanical Power Presses); OSHA1910.147 (Lockout/Tagout); and
the proposed Ergonomics Standard.
What agencies provide third-party verification?
These agencies include Underwriters Laboratory (to UL Standards),
Canadian Standards Association (to CSA Standards), and several European
agencies (to European Standards).
Neither OSHA nor ANSI provides any kind of verification services or seals
of approval.
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What is control reliability?
Control reliability is a term used and defined by OSHA and ANSI. The
equivalent term used by the European community is "Category 4."
Essentially, standards state that "A presence-sensing point of operation
device shall be interlocked into the control circuit to prevent or stop
motion if a hand or other body part is within the device's sensing field
during the hazardous portion of the cycle. The device shall be constructed so
a single component failure within the system does not prevent the normal
stopping action from being applied to the (machine) when required, but does
prevent the initiation of a successive cycle until the failure is
corrected."
In other words, a light curtain must be designed and constructed so it
detects a single component failure, sends a stop command, and prevents
reinitiation until the failure is corrected.
For more information, consult OSHA 1910.217 or ANSI B11.19.
When is a light curtain the best choice?
Light curtains are ideal in applications demanding frequent and easy access.
They should be rugged enough for industrial environments.
When no access is required, physical guarding can prevent anyone from
reaching over, under, around, or into the machine's hazardous area.
Electrically interlocked barriers with safety switches can be used when you
require infrequent, but fairly easy access.
No matter what, workers and passersby should never be left to assume or guess
which part of the machine is guarded and which isn't. Typically, this means
that open areas are guarded by presence-sensing devices, and closed areas by
physical guarding (fixed or interlocked). However, it should be obvious
which safeguard is being used.
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How does a light curtain work?
The light curtain's transmitter contains LEDs (light emitting diodes) that
send harmless, invisible pulses of infrared light to the receiver's PTs
(photo-transistors).
The PTs in the receiver detect each light pulse and convert it to an
electrical signal. The light curtain immediately signals the machine to stop
when any light beam is interrupted.
How can I be sure my interface with the machine's stop circuits is
control reliable?
Light curtains usually have two cross-checked captive contact (force
guided) mechanical relays. Typically they are normally open (N/O) outputs and
are connected in series with the machine's stop circuit. Some users prefer
one normally open and one normally closed output (1NO/1NC). When using
1NO/1NC and connecting to a single emergency stop string, the N/C logic has
to be inverted at the machine control. This inverting logic requires
careful consideration because it must also be control reliable.
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How important is safety distance?
Determining the correct safety distance is paramount to safety in the
workplace. Safety distance applies to any safety device that electrically
signals a stop, such as two-hand controls, electrically inter-locked
barriers/gates, and presence-sensing devices. A light curtain must be mounted
far enough away from the hazard so the machine will stop before the person
gets too close to the hazard.
There are established formulas for calculating safety distance. OSHA 1910.217
states that the safety distance from the light curtain's sensing field to the
pinch point must be no less than:
Ds = 63 inches/second x Ts
In this formula, Ds equals the minimum allowable safety distance in inches,
Ts is the worst case stopping time, and 63 inches per second represents the
established hand-speed constant.
By comparison, ANSI safety distance formulas are more stringent. One
additional requirement is called the "depth penetration factor"
based on your light curtain's object sensitivity. Object sensitivity is the
smallest object a light curtain can detect anywhere in its light field.
The OSHA or ANSI formula should be used as the basis for determining proper
safety distance in your application.
However, if you use a presence-sensing device as a perimeter guard where a
person could walk into the light path you might want to use a more generous
hand-speed constant.
What about height?
Once you've determined the correct safety distance, you should consider the
light curtain height. Your light curtain must be installed so someone can't
reach over, under, or around the light curtain and into the hazardous area of
the machine without being detected. This requires a light curtain that is the
proper height and at the proper safety distance, combined with ancillary
physical guards.
What's the optimum angle of divergence and acceptance?
The angle of divergence and acceptance refers to the size of the cone of
light emitted from the transmitter and how much of that light is detected by
the receiver. It relates to the possibility that light reflected off some
unintended surface (such as a shiny material or glossy surface on the machine
or plant floor) could cause an "optical" short circuit. A small
angle of divergence and acceptance means there will be a predictable plane of
protection, with no holes in the coverage. If it is too small, it may be
impossible to keep the transmitter and receiver properly aligned.
Industry and world standards have determined that +/- 2° is the optimum
angle. This angle ensures safety combined with ease of alignment and
tolerance to vibration.
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Do light curtains inhibit productivity?
No, effective safeguarding should actually enhance productivity while
reducing costs. Light curtains, for example, help to protect personnel without
obstructing visibility or interfering with operation. The easy, productive
way to work becomes the safe way. Insurance premiums may be reduced. With proper safeguarding,
workers also feel more comfortable and confident, and are less afraid of
being injured on the job.
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What's fixed blanking?
Fixed blanking causes the light curtain to become blind to stationary
fixtures such as a table or conveyor. Typically, there are two methods:
external blanking and internal, or programmable, blanking. If you use fixed
blanking and the obstruction is partial, safety distance will be affected
because the light curtain becomes less sensitive.
What's the difference between external and internal fixed blanking?
With external blanking, physical blanking windows are installed on the
receiver allowing stationary fixtures to protrude into the safety curtain's
light field. This leaves no question or doubt as to where an obstruction is
penetrating the sensing field.
Internal blanking is electronically programmed in the light curtain's control
circuitry and therefore may not be visible. Some light curtains use small
LEDs to indicate which beams have been internally blanked, while other light
curtains don't provide any visible indication. Internal blanking could be
hazardous if the beams being blanked are not obvious. Some light curtains
with internal blanking claim to have the ability to detect the presence or
absence of an obstruction. Unfortunately, no light curtain can determine
whether the obstruction is all the way from the transmitter to receiver (such
as a work table), or very narrow (such as a slim conveyor). Essentially this
could lead to a hole in the overall protected area.
As always, the rule of thumb is to optimize safety. Regulations require
that any type of blanking must be under supervisory control, the installation
must remain intact, and blanking must be obvious to avoid an unsafe situation
or misconception of coverage.
How does the floating blanking feature help productivity?
A floating blanking window allows a moving object to randomly obstruct
the light curtain's sensing field as long as it blocks only one beam at a
time. Some allow more than one beam to be interrupted. Any additional
obstruction within the field will immediately activate a stop command. This
is useful in applications where material must move within the sensing field
in a random pattern. However, the floating window should be used only when
material or parts take up no more than 1-1/8" within the sensing field.
Larger objects would block more than one light beam at a time and therefore
send a stop command. Note that the use of a floating blanking window will
affect safety distance because it alters the sensitivity of the light curtain.
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Why choose a rugged light curtain when my environment doesn't require it?
When selecting a light curtain, make certain it's rugged, reliable,
easy-to-maintain, and meets strict industry standards.
A good light curtain should tolerate tough environments because you're
counting on it for safety.
What does all this mean to me?
The best approach in selecting a control reliable light curtain is
usually the simplest. Choose a light curtain that meets all the safety
requirements and is easy to install and maintain. Be sure your light curtain
is rugged enough to withstand rough use and still ensure safety under all
conditions.
Look for a supplier with a proven track record in the light curtain industry.
Find out what quality control and testing procedures they employ. Also make
sure your supplier stands behind the light curtain after the sale.
These are just a few of the questions to consider. In the final analysis,
making workplace safety your highest priority should ensure that you make the
right choice.
For additional facts and information
Call
1-800-333-3282
to talk to our authorities on machine safety. They'll be
happy to answer your questions or provide a detailed assessment of
your requirements.
Our safety seminars reflect more than 25 years of hands-on experience,
involving tens of thousands of light curtain installations. We've also had a
prominent role in the development of related guidelines and safety standards.
Our machine safety authorities are a very knowledgeable -- and uncommonly
accessible -- source of practical advice on meeting current regulations and
industry standards.
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