The Importance of Using Proper Components

Maintenance people who buy components for equipment and machinery are faced with regulatory compliance issues. Only components of a certain quality must be used, and clearly, counterfeit components (see separate article on page 19) would not qualify.

Historically, when maintenance people were buying electrical components for equipment and machinery, they were looking for evidence that these components complied with Canadian requirements. Then, as today, a CSA label or an Electrical Safety Authority sticker should be evidence of compliance.

The meaning of the label or sticker is that the device has been investigated from the electrical shock hazard point of view only. People who specify or purchase such devices should be aware of this fact.

You should always ask suppliers what standards the equipment has been tested to and what the test covers.

For example, a CSA label on an electrical motor certifies that the motor is not going to electrocute a worker. CSA electrical certification, however, does not address the issue of stopping the motor when someone’s hand is in the danger zone.

New CSA standards for Machine Guarding, Press Safety and Robot Safety now require that safety components such as relays, stop buttons, interlocks, light curtains, etc., used in the safety circuits must be reliable components.

What does ‘reliable’ mean? The meaning is described by the new standards, as illustrated in the table below. These standards explain and classify a reliable safety system. The table demonstrates that the different safety system components require different levels of reliability.

For example, an area where there is a high risk to human life will have a greater standard of reliability than a lower-risk area. In Ontario, Occupational Health and Safety certification is done through PSRs (Pre-Start Health and Safety Reviews). Under the PSR requirements, any changes to safety components (other than routine maintenance) shall be reviewed by and signed off by a professional engineer registered in Ontario.

The province’s PSR requirements state that the standard applies when any of the following are used as protective elements in connection with an apparatus:

Safeguarding devices that signal the apparatus to stop, including but not limited to safety light curtains and screens, area scanning safeguarding systems, radio frequency systems and capacitance safeguarding systems, safety mat systems, two-hand control systems, two-hand tripping systems and single- or multiple-beam systems.

Barrier guards that use interlocking mechanical or electrical safeguarding devices.

A professional engineer would need to verify that these devices are appropriate for the application and meet the applicable standards based on the hazard analysis.

The performance of the equipment as far as safety is concerned is now linked to the criminal code by Bill C-45, which was passed earlier this year. It states that: “Every one who undertakes, or has the authority, to direct how another person does work or perform a task, is under a legal duty to take reasonable steps to prevent bodily harm to that person, or any other person, arising from that work or task.”

Bill C-45 requires that employers take steps to provide a safe workplace for their workers. Employers who fail to do so may face charges of criminal negligence under the code.

Criminal negligence occurs when an act or omission of an accused party shows reckless disregard for the safety of others where the accused is under a legal duty to act. Individuals who have been proven guilty may get up to 10 years in prison, and in the event the negligence has caused death, up to life imprisonment.

The use of only proper and certified components by maintenance personnel has become a very important issue, along with the issues of continence and negligence and of freedom and imprisonment.

It’s important to know the rules that must be followed to ensure compliance with regulations, and work with trusted vendors and suppliers to avoid inadvertently using counterfeit products.

Simon Fridlyand, P.Eng., is president of S.A.F.E. Engineering, a Toronto-based company specializing in industrial health and safety issues and compliance. He can be reached at 416-447-9757 or simonf@safeengineering.ca. For more information, visit www.safeengineering.ca.