2.1 Prevention and Control
2.1.1 Site Machine Guarding Plan
Each Microsoft location included in the scope of this program must develop a Site-specific Machine Guarding Plan (Site Plan). The Site Plan must be made available to any personnel potentially affected by the program, including employees, external staff, Microsoft OHS, or regulatory agency personnel. The Site Plan must include the following:
Program purpose and scope.
Identification of the Plan Administrator.
Personnel roles and responsibilities.
Documented procedures to ensure machinery at the location complies with all federal and state rules and regulations related to machine guarding.
Reliable procedures for checking whether all machinery is adequately guarded and for installing additional guarding where necessary.
Definitions of terms critical to an understanding of the program, or those terms not commonly understood.
Training records.
Incident investigations for all accidents, incidents, and near-mishaps that were directly or indirectly related to the use or absence of machine safeguards.
2.2 Risk Assessment
Risk Assessment is an evaluation of health and safety hazards in a work task and determining the likelihood of personnel injury or property damage resulting from those hazards. These analyses will usually include:
Interviewing supervisors, employees, and contingent staff.
Observing work practices.
Reviewing supporting documents that may include applicable regulations and guidelines and SOPs.
Conducting air and/or surface sampling, where occupational exposure limits are in question or as otherwise necessary.
Engaging process experts to review the tasks and develop safe work practices for operation and maintenance.
The Site Safety and Health Administrator will provide recommendations of appropriate engineering controls, administrative controls, work practices, PPE, or corrective action items. Supervisors must notify the Site Safety and Health Administrator when:
Changes are made to job processes that present additional hazards.
Audit corrective action items have been completed. For more information on the risk assessment process, consult the Microsoft Exposure Assessment Program
2.3 Machine Hazards
Machines present many hazards to the operator and other employees or contingent staff working in the area such as:
Mechanical motions
Chemical exposure
Electrical exposure
Thermal exposure
Hazardous noise levels
More information on non-mechanical hazards can be found in other Microsoft programs, including the Microsoft Chemical Management Program, the Microsoft Hazardous Energy Control (LOTO) Program, and the Microsoft Occupational Noise Control Program.
PPE and clothing can present hazards to the machine operator. The following items may present a hazard of entering the work space and pulling the operator into the machine:
Gloves
Long sleeves
Loose or baggy clothing
Loose hair or jewelry
For more information on the appropriate use of PPE, reference the Microsoft Personal Protective Equipment Program.
2.4 Types of Machine Safeguards
The basic principle of machine guarding is that the safeguard must prevent a person from contacting the hazard by going in, over, around, or through the safeguard(s) and reaching the point of operation. Not all machines have built-in safeguards from the manufacturer. When constructing and designing safeguards, consider factors such as maintenance, repair, and intended use. For more information on safeguard design and construction, please reference Appendix E.
2.4.1 Guards
Guards are designed to prevent access to hazardous areas of the machinery by placing a physical barrier between the operator and the machinery. There are four classifications of guards:
Fixed guards
Interlock guards
Adjustable guards
Self-adjusting guards
2.4.2 Devices
Devices are intended to prevent worker access to hazardous areas of machines. Devices can be classified into five categories:
2.4.3 Location/Distance Methods
To safeguard a machine by location or distance, the hazardous point of operation must be positioned so the hazards are not accessible to the workers during normal operation of the machine. This may be accomplished by:
Locating a machine away from areas where employees walk or work.
Placing enclosure walls or fences around the machine to restrict access.
Locating operator controls at a safe distance from the machine.
Requiring the use of tools to feed or remove parts into or from the machine.
2.5 PPE
Before determining the appropriate PPE for the specific task, refer to the Microsoft Personal Protective Equipment Program. The Site Safety and HealthPlan Administrator must work with managers to complete a Risk Assessment for each operation that may require guarding. The Risk Assessment process will identify the hazards and select the most appropriate type of hazard controls. The Risk Assessment should evaluate hazards from flying particles, moving parts, exposure to hazardous materials, and other hazards for the specific work task.
2.6 Training
Each location must train employees authorized to use or maintain hazardous machinery and ensure contingent staff have been provided site-specific information. Managers or supervisors must train authorized personnel at initial assignment and retrain if changes in procedures or work assignments occur. Microsoft OHS has defined training to meet regulatory requirements for machine guarding. To obtain training, contact Global OHS
The training program must include the following information:
An online overview of machine guarding requirements and hands-on instruction of the applicable Site Plan.
Applicable federal, state, or local regulations.
Summary of the Machine Guarding Program and how to access the written program.
Procedures for responding to and reporting an incident.
Instructions on how employees can request a risk assessment to determine guarding requirements.
Work on performed on equipment with guards removed or inactivated requires application of standard lockout/tagout practices. Personnel engaged in such activities must also complete Lockout/Tagout authorized user training.
2.7 Audits
The Site Plan must be audited annually and updated as needed to correct identified deficiencies. The Site Safety and Health Administrator must also review any past incidents related to machine guarding that occurred since the previous audit.
Managers and supervisors should be consulted about program improvement opportunities and involved in implementation of needed compliance improvements. The Site Plan should be updated as needed to reflect regulatory changes and improvements resulting from the annual audit.
2.7.1 Inspections
Guarding on all machinery should be visually inspected prior to use by the operator. Plan Administrators must conduct regular inspections of all machine safeguards as part of a preventative maintenance program. The inspection should look for the following:
Guards that are missing, defective, or worn out.
Guards that are out of place or not properly secured
Guards that have sharp points or edges that could pose a laceration hazard.
Guards that inadequately protect the operator (e.g., it allows a hand, finger or other body part to contact moving machinery, or it fails to stop flying debris).
