ASSE Practice Specialty Interview with Bruce Main
In this interview, Bruce Main, President of design safety engineering, inc. (dse) and member of the Packaging Machinery Manufacturers Institute (PMMI) B155.1 Standard Committee, discusses the standard, “Safety Requirements for Packaging Machinery and Packaging-Related Converting Machinery” (ANSI/PMMI B155.1-2006), and explains his predictions for how the revised standard will impact the manufacturing industry and the overall safety, health and environmental (SH&E) profession.
Please provide a brief description of your responsibilities as a member of the PMMI B155.1 Standard Committee.
I am a member of the PMMI B155.1 Standard Committee. The Secretary and Technical Director Fred Hayes and I had discussed ways to improve safety through design for machinery and how to develop a document that machinery manufacturers could use to build safer machines. At its first meeting, the B155.1 committee discussed options for improving the standard. The committee agreed that the risk assessment process should be used for the underlying structure of the document. I wrote the draft document that the committee used as a starting point. I started with the 2000 revision of B155.1 and added elements from several B11 machine tool standards and from other standards specifically related to machine safety. I then added the risk assessment process to the document. I also lifted content from ISO 1200 Parts 1 and 2 (safety of machinery) as well as from ISO 14121 (risk assessment) and rewrote that content in performance language. After a couple of revisions to get the document ready, it became the draft structure for the revision. The committee then worked to modify the language.
It is a substantial revision. The 2000 version mentioned hazard identification and risk assessment, but it did not give detailed instructions on how to do that, which was quite consistent with the state of the art at that time. The current revision of B155.1 presents an integrated risk assessment process so that readers know what they are required do to build and use safer packaging machinery.
One of the newer provisions of B155.1 is that it does not limit technology. It provides criteria to help suppliers and users of packaging machinery reduce risk to an acceptable level. If a machinery manufacturer or user develops a new solution to a problem using new technology not considered in the standard and can demonstrate that risk has been reduced to an acceptable level, you are good to go.
One of the more challenging themes we addressed was the global market for packaging machinery. PMMI is a global organization and addresses worldwide concerns. Packaging machinery manufacturers sell machinery in many countries, and they would prefer to be able to build to one standard and ship the machine anywhere. Similarly, the companies that use the machinery operate in many countries and often wish to ship machinery from one country to another. That became a theme for the committee: “Build to one standard, ship anywhere.”
We were writing in new territory. Clause 4 discusses the responsibilities of integrators, suppliers and end users because these groups wanted the clause to specifically delineate which party is responsible for safety concerns during the machinery lifecycle. We also wanted to create a document that reflects how machinery is designed, installed, maintained and used in the real world. We did not want a theoretical document with little practical use that did not address real safety problems.
We also wanted to make sure that end users found the standard’s language clear and easy to use and understand. Thus, the committee tried to write the requirements as clearly and simply as possible.
How has your experience with the Machine Tool Safety Standards Committee (ANSI B11) helped you as a member of the B155.1 Standard Committee? Did you find this experience valuable during the B155.1 standard revision process?
Yes, it was extremely valuable. I learned to formalize task-based risk assessment through my work with B11 TR3, which was published in 2000. I am currently the ASSE delegate to the B11 Accredited Standards Committee, thus I have witnessed the challenges in standards development that committees must manage. I am also a technical expert to the U.S. delegation revising the ISO 14121 standard on risk assessment. These experiences helped me better understand the constraints and opportunities of standards development. It takes a significant logistical and technical effort to keep things on track. In B11, I saw how problems manifested and how subcommittees worked together to solve these conflicts and to arrive at consensus. Understanding how subcommittees write text on similar themes helped me in my experience with the B155.1 standard.
Another benefit was the emphasis on end-user clarity. In B11, we place a great emphasis on ease of use and clear language. In B155.1, we wanted to make it easy for the average end user to understand the language and intent of the standard.
How do you predict the revised B155.1 standard will impact the manufacturing industry and the overall SH&E profession in the long term?
B155.1 applies to both suppliers and users of packaging machinery, thus it will touch many people. In terms of the SH&E profession, I think it will serve as a template for how to integrate safety in the design process and for demonstrating the value of risk assessment. When you conduct risk assessment early in the design process, you have much greater opportunity to reduce risk through design changes and engineering controls rather than through administrative or behavioral measures. The risk assessment process in B155.1 also provides a good mechanism for communication between engineers, safety practitioners and front-line workers. Engineers often are skilled in developing creative risk reduction solutions to known hazards. Safety practitioners are often skilled at identifying hazards. Operators and maintenance personnel know the tasks they perform better than anyone else and often have a very good appreciation for how systems could be improved to make their tasks easier and safer. So the task-based approach to risk assessment can help everyone improve the system because it focuses discussions around tasks, hazards and risk.
Safety personnel will play a key role in determining the hazards associated with tasks. This standard will help drive risk-based decision-making. So the SH&E profession will need to move with the standard and become even more involved in preventing machinery hazards through design.
DSE provides software, training and consultation to help companies identify hazards and reduce risks. From your perspective, why is risk assessment so important in the manufacturing industry in particular?
Competitive advantage. We see that with customers who want to integrate the process and treat results as competitive and confidential information. We are able to work safety into the design process through tools like our software, which allows you to make improvements so that people can work better, faster, cheaper and safer. Our software facilitates a faster and deeper analysis than you could do before with paper, checklists or basic spreadsheet methods. Risk assessment provides competitive advantage in the marketplace, and we are beginning to see more and more customers recognize these positive results now.
It will help reduce injury and accident rates within the manufacturing industry because it will allow us to identify more hazards early on in the design process, and it will help us find ways to better reduce the risks associated with these hazards. Both suppliers and users will work through the same process and talk the same language. If you identify certain maintenance tasks that are difficult to do because there is no access or you have to take the machine apart, engineers will be able to modify the design to allow the process to be performed quickly, safely and more easily. As end users begin to ask their machinery suppliers for risk assessments, they will greatly benefit from working through the same process.
It is very challenging for the machinery manufacturing industry to meet different standards. If you sell or use a packaging machine in one country and then take it to another country with safety requirements, it can become very cumbersome and costly to modify the machine. This is why “build to one standard, ship anywhere” is a central theme of the B155 standard. In many respects, I think the B155.1 is at the leading edge of machinery safety standards.
Does DSE assist its clients in implementing the revised B155.1 standard when necessary? Please explain.
Yes, we do. As a consulting firm performing risk assessment work, we help clients implement the standard through software, consultations and hands-on, two-day training sessions, which are done onsite. The response has been very good. The sessions get our customers up to speed on the risk assessment process quickly, and the two-day format allows them to learn by doing so that they can get some risk assessment work done. Most manufacturers make good products and machinery, and they verify and document that their decisions are good. Also, as they go through this process, they can identify hazards they might not have seen before. Engineers are not always familiar with maintenance tasks, so this helps them understand what tasks and hazards are present and create better solutions. dse helps companies implement the standard and shortens the learning curve for them to do so.
Do you feel that the manufacturing industry could benefit from other similar standards in the future? Why or why not?
Yes, I do, and it is already happening. The B11 General Safety Requirements closely follows the B155 approach. Many other standards, such as ANSI Z10, ANSI Z244.1, SEMI S10, ANSI/RIA R15.06 and many others now include requirements for risk assessment. B155.1 lends itself to use in other industries because much of the standard is not specific to packaging machinery. When we took B155.1 to the machine tool industry, it worked very well. B155.1 includes a generic risk assessment process that lends itself well to other standards and industries. Other standards organizations are using that format, and we benefit from sharing. We are also seeing some movement in Europe and ISO standards in the integrated risk assessment direction of B155.1.
What advice do you have for manufacturers who wish to incorporate this standard into their safety practices?
This is a journey, not an event. You do not just decide one day to conduct a risk assessment and be done. The standard will impact the way you do business and will lead competitive advantage. Our clients find that once you start doing risk assessment, it does not take long to see the positive results that come from the process. Some customers use the results of their risk assessments as a sales and marketing tools for their company. They have seen productivity and sales gains through this effort..
Companies need to implement this standard much as they would introduce any new process to their organization. Begin with pilot projects to figure out the best way to adapt the methodology to your organization. Risk assessment works in nearly every organization with which I have worked but not always in the same way. Once you figure out how the standard can best be used in your organization, you can roll it out company-wide.
The biggest factor is just to get started. It does not happen overnight, and you will not be an expert after your first attempt. Once you get started and begin to see success, you will see benefits. Integrating risk assessment early in the design review process allows you to see what still must be addressed and allows you to make changes as the design matures. The momentum of risk assessment makes it pretty clear that the B155.1 process works. Both PMMI and dse offer training sessions to help companies explore the standard and evaluate how to jumpstart it in their organizations.
Bruce Main is the President of design safety engineering, inc., a Michigan-based engineering consulting firm specializing in risk assessment and safety through design. A professional engineer and certified safety professional, Main holds mechanical engineering degrees from the Massachusetts Institute of Technology and the University of Michigan, and a master degree in business administration also from the University of Michigan.
He served on the Advisory Committee for the Institute for Safety Through Design, and he is a member of several industry committees on risk assessment. He is a technical expert to the U.S. delegation on Technical Committee 199, Working Group 5, which is revising the ISO 14121/EN 1050 risk assessment standard for Europe. He is also the primary representative to the B11 Committee (machine tool industry) on behalf of the American Society of Safety Engineers.
Main is a member of several professional engineering and safety organizations and has authored numerous articles, papers and books, including Risk Assessment: Basics and Benchmarks. He frequently lectures on risk assessment and safety through design at industry and educational institutions. He can be reached through www.designsafe.com.