Safety engineers must take their ‘authority’ role seriously
Ontario and Nova Scotia have recently introduced regulations mandating owners or lessees of certain hazardous equipment — or equipment used in hazardous processes — to obtain a report bearing a seal and signature of a professional engineer. In Ontario this regulation known as a "Pre-Start Health and Safety Review" (it was formerly called a "Pre-development review").
A engineer would need to get involved in such an inspection process involving any machine where a safety interlock or light curtain is required, or any process where flammables or combustibles are handled. There are no other requirements for third-party review or certification. The buck stops right there, with the inspection engineer.
I view the engineer as playing the role of what is often called the "authority having jurisdiction". The authority having jurisdiction is defined as an organization, office or individual responsible for approving equipment, an installation, or a procedure. In other similar cases like the approval of electrical installations or building construction, the authority having jurisdiction would be an electrical inspection body, or a municipality. Approval process usually consists of verification of equipment, machines or installations, in accordance with nationally recognized codes and standards.
A list of acceptable codes and standards is usually included in various regulations governing process or equipment. The majority of industrialized countries have their own standards for a specific product. The European community has adopted a list of harmonized standards acceptable throughout Europe. In Canada, certain American standards are acceptable together with our own. However in some instances our standards are simply not available.
A good example of a product governed by ambiguous or non-existent standards would be a light curtain, which is commonly used as a guarding device. There are two CSA standards related to light curtains, CSA-Z142 and Z432. Neither of them would require examination of the light curtain from a safety performance point of view. In other words, the current standards would require examination of the device from an electrical shock hazard point of view — but not from performance point of view.
Compliance to the standard will confirm that a worker may not be electrocuted by the light curtain, but will not confirm that the injury will be prevented by the device. The obvious question, then, is why do we need a light curtain in the first place? The answer is that it should be a useful safety device, provided it has been evaluated from a performance safety point of view. There are European standards, which evaluate the performance of such devices, but these standards are not recognized here in Canada. Who is to say that, for example, the prEN 999 Installation Condition draft Standard is a good document? I alone cannot make such a judgment. There is, however, a process by which international standards are evaluated and accepted here.
Many Canadian codes such as the Building Code, Fire Code, and Electrical Safety Code, have cross -references to acceptable standards. But many of them are not Canadian. The Occupational Health and Safety Act in Ontario, for example, does not provide any cross-references to applicable standards mentioned in the Act. Further more, the recently-changed section 7 of "Reg. 851 for Industrial Establishments", known as Ontario Regulation 528/00, has cross-references to current applicable standards without mentioning them.
Would a machine manufactured in Mexico, where there are no standards, be acceptable here? In a catalog of a major light curtain supplier manufactured in Japan, I saw a statement saying that such a device is not allowed to be sold in Japan. It is, however, widely used and promoted here. It bears a CSA label. The meaning of the label is that the device has been investigated from an electrical shock hazard point of view only. People who purchase such devices should be aware of this fact. Purchasers should always ask the supplier about what standard it has been tested to, and what that standard covers. What can we do to change the situation? The answer is simple: Take a proactive approach.
Other codes with cross-references to applicable standards were developed in the past. People who write Occupational Health and Safety Acts should follow their examples. We do not need to wait for a disaster to happen to change our existing regulatory requirements.
Unfortunately, in the past that is often what it took to bring the change about. Spectacular fires, for example, brought the development of codes and standards to the present level. The Walkerton water-supply disaster brought changes to our drinking water requirements. The infrastructure exists to properly address Occupational Health and Safety issues today. We do not need to wait until something happens and then change our requirements. Engineers acting as an authority having jurisdiction should be in the forefront of this change.
Simon Fridlyand, P.Eng., is the president of S.A.F.E. Engineering, a company specializing in PDRs and audits for fire code compliance. You can reach him at (416) 447-9757.