ANSI Standards: Are they Really Voluntary?

By Joe Lazzara, Scientific Technologies Inc.

The ANSI Organization has a difficult task – how can they promulgate consensus standards, written entirely by volunteers in subcommittees, with no enforcement authority, and still win the respect of the machine builders, users and labor? In short, how does ANSI avoid being the Rodney Dangerfield of safety standards?

When faced with the confusing task of helping a customer understand the indeterminate complexities of OSHA machine guarding, I encourage our sales people to use an appropriate ANSI standard whenever possible, as they are usually easier to understand. My favorite is ANSI B11.19, Safeguarding When Referenced by the Other B11 Machine Tool Safety Standards – Performance Criteria for the Design, Construction, Care and Operation. (Admittedly, the one thing I don’t like about B11.19 is the name!) For example, compare the sparse few paragraphs on general machine guards in OSHA 1910.212 with a more complete discussion of several pages contained in the ANSI document. I also find the explanatory information in the right hand column of the B11 standards provides the reader with a practical understanding of the machine guarding concepts. This is another advantage over the OSHA regulations, where the text is often reminiscent of the IRS instructions for Form 1040!

As I discussed in my prior article "Preparing for the ANSI Onslaught", an update of B11.19 is one of the 10 new or revised standards to be published in the next 18 months. Given what I have seen of other revised standards, I am sure this update will make a good standard even better. Copies of ANSI B11.19 can be purchased directly from The Association for Manufacturing Technology (AMT) at 703-893-2900.

Voluntary or Not?
One area of confusion for safety professionals, engineers, builders and users involved with the implementation of the ANSI documents revolves around the enforceability of these consensus standards. After all, these are just voluntary standards, right? Well, the real answer is yes – and no. Technically, the ANSI standards are considered voluntary consensus standards and are not written as laws or regulations. In fact, the subcommittees that create the standards have no enforcement authority, much to the relief, I am sure, of the subcommittee members!

The voluntary status of the standards can become a bit cloudy when OSHA adopts ANSI standards by reference. This is the case, for example, with OSHA 1910.215, Abrasive Wheel Machinery. The section, 1910.215(b)(12), requires abrasive wheel machinery guards must conform to the ANSI B7.1 standard on Abrasive Wheels.

Let’s use another example to illustrate how the ANSI standards and OSHA regulations can interact. Assume that an OSHA compliance officer cites a company under 1910.212(a)(3)(ii), for failure to safeguard a machine at the point of operation. One way the company can abate the citation is to demonstrate the machine is guarded according to the appropriate B11 standard. In fact, the text in 1910.212(a)(3)(ii) includes, "The guarding device shall be in conformity with any appropriate standards…" Thus, here is a case where the voluntary B11 standard is used to correct a hazardous situation, and reduce a citation issued under the mandatory OSHA regulations.

ANSI standards can also be interpreted as implicit regulations through our American legal system. The standards make a wonderful reference on how a machine should be, or more likely in the case of a trial, should have been, guarded. Employers or manufacturers who do not comply have a potential liability exposure if an ANSI standard indicates a method of machine design, operation or safeguarding which may have prevented an injury. It would be difficult to persuade a jury that a particular document is "just a voluntary standard" while the opposing lawyer advocates it is really the Holy Grail of safeguarding.

ANSI and OSHA have formalized their relationship in a one page Memorandum of Understanding. (The full text can be found at:
http://www.osha-slc.gov/MOU_data/MOU19910521.html.) The following key phrase describes how OSHA will use the ANSI organization in future standard development: "ANSI will furnish assistance and support and continue to encourage the development of national consensus standards for occupational safety or health issues for the use of OSHA and others." This certainly sets the stage for continued integration of OSHA regulations and ANSI standards and cooperation between these two organizations.

This concludes the third in a series of articles on the ANSI standard development process, the relationship with OSHA and the further impact of these consensus standards on American industry. Next time, we will look how ANSI manages to keep their standards up to date with changing technologies and industry trends, user expectations and new safety requirements. In the meantime, be safe out there!

Lazzara on Automation Safeguarding is a monthly column written for Safetyonline.com and Plantautomation.com.

Joe Lazzara is president and CEO of Scientific Technologies Inc. (STI, Fremont, CA), the largest provider of automation safeguarding solutions in North America. Lazzara began his career with Hewlett Packard in 1973 where he had responsibility for safety and environmental issues for one of HP’s largest divisions. He joined STI in 1981 as vice president and became president in 1989 and CEO in 1993. Lazzara received a bachelor’s of environmental engineering degree from Purdue University and an MBA from Santa Clara University.