When a business owner or leader plans a capital project, whether it's building a new facility, expanding a warehouse, or installing a state-of-the-art production line, they are focused on budget, timeline, and protecting and optimizing the use of capital.
However, there is a common, high-cost blind spot that frequently derails these projects: the Retrofit Premium.
Too often, organizations purchase and install industrial machinery or complete facility construction, only to discover post-installation that the equipment fails to comply with local codes, leads to or contributes to violations of OSHA standards, or introduces intolerable, unmanaged physical safety or health hazards to workers.
At this late stage, project funds are often exhausted or severely limited, leaving managers in an unenviable position. Attempting to change programming, retrofit machine guarding, install specialized exhaust ventilation, or provide safe work access, surfaces, and fall prevention after the fact can often cost significantly more than addressing those hazards during earlier design phases. Even worse, late-stage physical modifications can frequently cause unnecessary stress, project delays, unscheduled production shutdowns, poor trade-off decisions, and immediate operational inefficiencies.
The "OSHA-Approved Machinery" Fallacy
Many purchasing departments fall into the trap of assuming that because they are buying machinery from a reputable commercial supplier, the equipment must be "OSHA-compliant."
Consider this standard truth: In reality, in the US, there is no such thing as an "OSHA approval" or certification process for industrial equipment. While OSHA has standards that provide some prescriptive requirements, OSHA does not test, certify, or approve machinery. There is no OSHA function to “certify” items for sale on the market.
While some product literature may loosely or even directly claim to be OSHA-compliant, that would be a manufacturer’s claim rather than a direct certification from OSHA itself.
I’ve seen many cases where a company’s engineering or purchasing departments, even for somewhat integrated or complicated processes or machinery, simply presume that a manufacturer or supplier “must” be proposing to sell it items that will be safe for their workers to use. “After all, it’s for sale on the market, right?” Well – my intention is not to get deep into safety theory here. In reality, that thinking process can create extra risk for the organization.
Products can be designed by people from many backgrounds and with varying understandings of industrial processes, activities, and risks. The potential risks from the use of things like newly integrated process lines and machines can vary based on installation, how integration is accomplished with adjacent processes, how machinery and equipment are actually used (task-based factors), and other variables.
In my experience, I’ve seen suppliers of various types of manufacturing equipment submit lowball sales proposals to organizational leaders who may not understand key end-user-type safety requirements and principles related to what they are buying. The proposals had omitted (for example) proper physical safeguarding, less-than-desired electrical safety controls, inadequate noise control, the generation of unacceptable levels of chemical emissions, and other things. Sometimes I've heard suppliers say they figured that if the customer wanted more, they'd be able to charge more for "add-on" safety features later. However, the responsibility for employee safety and OSHA compliance ultimately rests with the employer who purchases and oversees the operation of the processes or equipment. That is not to say that employees don't have safety responsibilities, in context. They do. But it's the employer who is running the business, making procurement decisions, and is responsible for meeting the obligations of the OSHA General Duty Clause 5(a)(1) (or State Plan equivalent), which requires that each employer:
"...shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;"
Sector Solutions: Bridging Manufacturing and Facilities
Rather than viewing safety as an after-the-fact compliance chore, forward-thinking organizations apply a systems engineering discipline known as Prevention through Design (PtD) to eliminate or minimize hazards before use. There is an ANSI/ASSP consensus standard on this topic referred to as ANSI/ASSP Z590.3, Prevention through Design – Guidelines for Addressing Occupational Hazards and Risks in Design and Redesign Processes.
At a high level and to get to a “so what about it” point quickly, this cross-industry methodology can protect capital investments across important industrial sectors:
- In General Industry & Manufacturing: Before purchasing new CNC machines, conveyor systems, or robotic work cells, engineers and OSH specialists conduct design reviews (typically at the 30%, 60%, and 90% completion stages). By reviewing things like guarding, accessibility, electrical control reliability and ergonomic workstation heights against OSHA requirements (where they exist) and consensus standards at various points in time (e.g., during design phases, assembly at a supplier location, pre-shipment, during installation and trial production) - companies ensure the processes/machinery is safe, productive as intended, and conforming to applicable regulations and adopted standards. All before there is the potential for Pandora’s box to be opened.
- In Facilities & Construction: During construction or major renovations, planning teams evaluate the safety of the workers building the structure, as well as the long-term maintenance staff who will service it. Simple upfront design choices—like building permanent, safe catwalk access to elevated valves or installing certified fall-protection anchor points—eliminate the need for costly temporary scaffolding or hazardous work-at-height workarounds for years to come.
Low-Cost PtD Integration for SMEs
In most cases, while implementing PtD processes requires some intentional effort, it does not require an army of engineers or massive budgets. Smaller and medium-sized enterprises can incorporate PtD principles into their normal business processes through some pragmatic steps:
- Vendor Safety Specifications: Engage in discussion with your equipment vendors regarding their risk assessments, equipment installation reviews and approval processes, and special safety considerations and safety specifications that your organization may have as a standard condition of bidding. Letting your suppliers know that you care about these types of things can be an important part of your processes.
- Operational Change Control (MOC): Establish a simple internal rule that any physical modification to processes, equipment, or facility layouts must undergo a brief review to identify potential unintended safety impacts before work begins.
- A Safety Buy-Off Process: Implement a formal "commissioning" or "buy-off" checklist that requires a multi-disciplinary team (including maintenance and operators) to inspect and approve new installations before they are officially released to production. You may or may not be amazed at how many people I’ve spoken to in facilities who, when talking about newly installed (or modified) equipment, comment to the effect of, “if they had only asked ME.”
The Takeaway: Address hazards at the drawing board, not on the factory floor or construction site. Treating safety as an upfront design parameter rather than a late-stage retrofit protects your workers' health, secures your operational uptime, and preserves your corporate capital.
To learn more about practical aspects of structuring and implementing a Prevention through Design (PtD) process within your own organization, see Gregory G. Zigulis’s book, Health and Safety Programs in Small and Medium-sized Businesses: Setting Them Up and Making Them Work Effectively. Chapter 11 of the book provides an overview of PtD concepts and the value of application. Greg actively serves on ANSI/ASSP standards committees, including the ANSI/ASSP Z590.3. The book is available on Amazon at https://a.co/d/0gdjchrY. For customized assistance, contact Gregory G. Zigulis, MS, MBA, CIH, CSP, at Sixth Sense Safety Solutions.