Editor's note: Worker safety has always been a primary concern of molders. However, current ANSI/SPI safety standards, given their cost of compliance, are creating waves in the molding community. The following is the first of a two-part series that explores the issues surrounding the new standards. Look for Part 2 in the July issue of IMM.
Nothing is more important than worker safety. On that, U.S. injection molders, their molding machine suppliers, and the industrial standards organizations in Washington say they fully agree. But when it comes to whether or not the latest ANSI/SPI safety standard for molding machines merits the cost of compliance, many agree to disagree.
There is a considerable amount of concern and controversy in the field, and not just over how best to interpret what some claim are confusing and often conflicting requirements. How will the new rules be enforced? Who bears responsibility for an old press that might have changed hands several times, especially one that might be the abandoned orphan of a now-defunct machine builder? Is the nonprofit ANSI cashing in on safety by charging $32.00 to download a copy of the standard?
By far, the biggest concern is over the impact of conformance costs on the bottom line. Some machinery OEMs admit that it costs them more to build conformity into new presses. One of the largest invested more than 5000 man-hours developing solutions to upgrade its huge U.S. customer base. But many complain that increasing prices to absorb the added cost is tantamount to committing competitive suicide in today's market.
In addition to the potentially big bill for upgrading older machines, plus the safety markup on new ones, molders complain that compliant presses add to cost by slowing production, a disastrous consequence with lead times shrinking as fast as they are today. Regrettably, the standards put the owners of molding facilities and their suppliers in the unenviable position of weighing the cost of worker safety against the cost of lost profits.
|The ANSI standard and how it can affect you|
|ANSI B151.1-1997 Sections 6 and 8 went into effect on July 22, 1997. This standard sets minimum safety requirements, primarily in access guarding and machine safety interlocks, for horizontal injection molding machines built on or before that date. Owners and users of such presses were required to bring their machines into compliance and were granted a three-year grace period to do so. The grace period ended on July 22, 2000. The latest ANSI updates were drafted by the Injection Molding Standards Development Committee of the SPI.
Should an OSHA inspector determine that an injury could have been averted if the plant owner had complied, that owner could be subject to costly tort liability. OSHA inspectors frequently refer to ANSI standards during plant inspections and accident investigations. ANSI standards are not government mandates. But OSHA inspectors cite nonconformities as evidence that safety hazards exist in a plant. ANSI stands for the American National Standards Institute of Washington, DC (www.ansi.org), a private, nonprofit organization that administers and coordinates the U.S. voluntary standardization and conformity assessment system.
"Personally, I am a big believer in safety first. But this standard takes it to the absurd. The additional guarding required on the machines literally makes it impossible to set them up." The vice president of manufacturing at a midsized U.S. molder summarizes sentiments expressed by several others contacted for this report. "Running water and hydraulic hoses requires us to cut clearance holes in the guards. In addition, interlocks have been added to restrict the operation of the screw, making it extremely difficult to service the screw and barrel."
A smaller-sized U.S. molder speaks of how the standards were a major part of a recent shopwide safety inspection carried out by the company's workers' compensation carrier. "Since some of our presses were manufactured before these standards were in place, some of them were cited for insufficient guarding. These were made compliant using Lexan PC sheet to close the part drop area." This molder continues by posing a perplexing question.
"Were these machines actually unsafe? We have not had a serious lost-time injury involving a molding machine. We have made our machines less prone to worker injury by complying with these new standards. But I think you can get a false sense of security if you ignore safety training." This source believes machines can be guarded so well that they can make a very active process look a little bit too passive. "Without worker training, injuries will still occur."
|Historical highlights of ANSI B151.1|
SAFETY GUIDELINES are first published in the April 1973 issue of Plastics Machinery & Equipment magazine. Domestic machine builders begin compliance.
ANSI B151.1-1974 draft becomes the proposed 1976 Standard.
ANSI B151.1-1976, approved in June 1976, covers safety requirements for the manufacture, care, and use of horizontal presses, including standardized requirements for the following:
ANSI B151.1-1984, approved in October 1984, updates the 1976 ANSI Standard to add requirements for the following:
ANSI B151.1-1990, approved in January 1990, updates the 1984 ANSI Standard to add requirements for the following:
ANSI B151.1-1997, approved July 1997, updates the 1990 ANSI Standard Sections 6 and 8 to add requirements for the following:
Based on information provided by Epco LLC (Fremont, OH).
Compliance Cost Calculations
Polycarbonate sheeting may not be enough for some. A spokesperson for a molder with more than 500 machines in its U.S. inventory estimates that compliance could cost the company far more than $1 million.
"To meet the ANSI/SPI B151.1-1997 machine standards, we are extending the operator gate with sheet metal and installing a ratchet-style drop bar. Although these all are customized projects, we estimate that the average for each is about $2000 in cost.
"So, using my own brand of fuzzy math," this molder continues, "I see us running up a total cost for the machine standard of about $1.2 million by the time we get it all done."
A U.S. supplier of European-built molding machines argues that complying with the latest ANSI standard puts no inordinate cost burden on the company's products.
"Speaking purely from a very selfish standpoint, there are a lot of things we have already been doing to comply with European safety standards that have exceeded standards like these. We've had things like a cycle-start button forever, for instance." A U.S. supplier of Japanese presses agrees, pointing out the manufacturer's overkill engineering of its injection barrel safety guarding as an example.
Throughout the industry, there is curiosity about who votes on the standard and how well they know a molding machine. Says one supplier, "I am not sure those involved in the voting process would even be able to describe some of the things we describe as being mutually agreeable."
"Some of the requirements might be academically sound. Nevertheless, they can pose dilemmas in the real world," this source continues. For example, according to the standards, if a machine has a shutoff nozzle, is running in manual mode, and is stopped by opening the safety gate, the shutoff should be open.
"The material droolsâno harm, no foul. The dilemma is in having the machine running in automatic. Say, if a part traps and triggers mold protection, is the machine just supposed to sit there with trapped plastic in the barrel, burn it, build up pressure, and blow the hopper off the press? We need a clarification of the meaning behind some of these requirements."
Another supplier adds, "All functions are supposed to cease when you open the gate. That really poses no problem with hydraulic machines. But there are no hydraulic safeties on all-electrics. The electric drive motor itself dies if you are running it semiautomatic." This source also takes issue with the guarding requirements, saying, "They make criminals out of customers who remove them to speed setup or service."
Work began on standards compliance in 1997 and most domestic OEMs reportedly shipped new machines in full compliance the following year. Today, many machinery suppliers provide far-reaching safety auditing and standard compliance retrofit services to customers. Still, one supplier complains that customer service requests can go too farâmolders asking suppliers to remove ANSI-compliant guarding after receiving a new machine, for instance. "Could you imagine the lawsuit of someone getting hurt after the manufacturer removed a safety item?" this source queries. "The lawyers would have a field day."
Why it's Worth it
With much exasperation, this press supplier continues, "Being a member of the SPI/ANSI Safety Committee, it is amazing to hear the comments from the molders every time a new requirement is introduced. It brings to question, why is the SPI doing this? A manufacturer has problems, too, especially when the cost increase does nothing to better itself against its competitors. But we could accept this if the molders were for it."
"It is important to note that the SPI committee that drafts the standards is made up of representatives from the machinery manufacturers, as well as molders," another supplier reminds us. "This is to ensure safety without compromising machine capabilities."
So, why is the SPI doing this? One supplier answers, "Some people call them 'necessary evils' because they raise the cost of machinery and plant operations. However, those costs are small compared to the cost of injury or death on the job. At the speeds, pressures, and temperatures injection molding machines operate," this source concludes, "I would appreciate the safety features if I were a machine operator."