Safety training obligations for employees.

 

Safe Use of Machinery and Equipment

1. Introduction

Safe use of machinery and equipment is an essential part of occupational health and safety. Machinery such as presses, conveyors, cranes, forklifts, cutting machines, drilling machines, electrical equipment and automated production systems can cause serious injuries if they are improperly designed, installed, operated, maintained or supervised.

The basic principle is that an employer must take reasonable and legally required measures to protect workers from foreseeable risks arising from machinery and equipment. Safety is therefore not limited to providing protective equipment; it includes risk assessment, guarding, maintenance, training, supervision, inspection and emergency arrangements.

In Japan, machinery safety is primarily connected with the Industrial Safety and Health Act (ISHA) and its subordinate regulations. Employers must take measures to prevent workers from suffering injuries or health problems arising from work equipment and working methods.

2. Meaning of Safe Use of Machinery

Safe use of machinery means operating, maintaining, cleaning, repairing and inspecting machines in a manner that minimizes the possibility of injury, death or occupational illness.

It covers:

  • Proper machine installation
  • Machine guarding
  • Emergency stop mechanisms
  • Regular inspection and maintenance
  • Safe operating procedures
  • Worker training
  • Lockout and isolation of hazardous energy
  • Personal protective equipment
  • Warning signs and instructions
  • Competent supervision
  • Reporting and correction of defects

3. Major Hazards Associated with Machinery

A. Mechanical Hazards

Workers may be injured by:

  • Moving parts
  • Rotating shafts
  • Gears
  • Belts
  • Chains
  • Cutting blades
  • Crushing points
  • Shearing points
  • Entanglement

For example, loose clothing may become caught in a rotating machine.

B. Electrical Hazards

Electrical machinery can cause:

  • Electric shock
  • Burns
  • Fires
  • Explosions
  • Electrocution

Electrical systems should therefore be properly insulated, grounded and maintained.

C. Falling Objects

Machines used in construction, warehouses and factories may cause objects or components to fall.

Examples include:

  • Crane loads
  • Machine components
  • Stored materials
  • Tools
  • Suspended equipment

D. Noise and Vibration

Long-term exposure to machinery noise or vibration may create occupational health risks.

Employers should therefore control exposure through:

  • Engineering controls
  • Isolation
  • Maintenance
  • Work rotation where appropriate
  • Hearing protection

E. Heat and Dangerous Substances

Some machines generate extreme heat or release:

  • Dust
  • Fumes
  • Vapours
  • Chemicals
  • Metal particles

Appropriate ventilation and protective measures are necessary.

4. Risk Assessment Before Using Machinery

A proper risk assessment should be conducted before machinery is introduced or used.

The assessment should identify:

  1. What machinery is being used?
  2. What hazards exist?
  3. Who may be exposed?
  4. How serious could an accident be?
  5. How frequently could exposure occur?
  6. What controls are already available?
  7. What additional controls are necessary?

The assessment should also consider workers who may require additional protection, including inexperienced workers and workers performing maintenance or cleaning.

5. Machine Guarding

Machine guarding is one of the most important safety measures.

Guards should prevent workers from coming into contact with dangerous moving parts.

Examples include:

  • Fixed guards
  • Interlocking guards
  • Adjustable guards
  • Safety barriers
  • Light curtains
  • Protective enclosures

A guard should not be easily removed during ordinary operation.

Where removal of a guard is necessary for maintenance, the machine should normally be stopped and isolated from its energy source before work begins.

6. Safe Operating Procedures

Every machine should have clear operating procedures.

These should explain:

  • How to start the machine
  • How to operate it
  • Maximum operating limits
  • Prohibited actions
  • Emergency stopping procedures
  • Cleaning procedures
  • Maintenance procedures
  • Shutdown procedures

Workers should not be permitted to operate machinery without adequate instruction and training.

7. Training and Competency

Employers should ensure that workers understand:

  • Machinery hazards
  • Operating instructions
  • Safety devices
  • Emergency procedures
  • PPE requirements
  • Maintenance restrictions
  • Reporting procedures

Training should be appropriate to the worker's actual duties.

Simply giving an employee a written manual may not be sufficient where the worker does not understand how to operate the equipment safely.

8. Inspection and Maintenance

Machinery should be regularly inspected and maintained.

Inspection should cover:

  • Guards
  • Emergency stops
  • Electrical connections
  • Safety switches
  • Moving components
  • Hydraulic systems
  • Brakes
  • Cables
  • Warning systems

Defective machinery should not continue operating where doing so creates a significant safety risk.

Maintenance records should also be preserved.

9. Lockout and Energy Isolation

Maintenance workers face particular risks because machinery may unexpectedly restart.

Before repair or maintenance, dangerous energy sources should be identified and isolated.

Potential energy sources include:

  • Electricity
  • Hydraulic pressure
  • Pneumatic pressure
  • Steam
  • Compressed air
  • Stored mechanical energy
  • Gravity

The machine should be safely stopped and isolated before maintenance begins.

10. Emergency Stop Systems

Machinery presenting serious hazards should have appropriate emergency stopping arrangements.

Emergency controls should be:

  • Easily accessible
  • Clearly identifiable
  • Functional
  • Regularly tested

Workers should know how and when to use them.

However, an emergency stop should not be treated as a substitute for proper guarding and preventive safety measures.

11. Personal Protective Equipment

Depending on the machine and risk, PPE may include:

  • Safety helmets
  • Safety glasses
  • Face shields
  • Protective footwear
  • Gloves
  • Hearing protection
  • Respiratory protection
  • Protective clothing

PPE is generally an additional protective measure. It should not replace reasonably practicable engineering and administrative controls.

12. Employer's Responsibilities

Employers have important responsibilities relating to machinery safety.

These include:

1. Providing safe equipment

Machinery should be appropriate for the intended work and maintained in safe condition.

2. Providing information and instructions

Workers should understand the risks and safe operating methods.

3. Providing training

Workers should receive adequate safety education.

4. Conducting inspections

Machines should be inspected according to applicable legal and technical requirements.

5. Maintaining safety devices

Guards, interlocks and emergency systems should remain functional.

6. Supervising workers

Employers should monitor whether safety procedures are actually followed.

7. Correcting dangerous conditions

Identified defects should be corrected promptly.

13. Employee Responsibilities

Workers also have responsibilities.

They should:

  • Follow safety instructions
  • Use machinery only when authorized
  • Wear required PPE
  • Never deliberately bypass safety devices
  • Report defective equipment
  • Follow maintenance procedures
  • Keep the working area clean
  • Use emergency procedures when necessary

A worker should not remove a safety guard simply to make production faster.

14. Japanese Legal Framework

In Japan, machinery safety is principally addressed through the Industrial Safety and Health Act and related regulations.

Important areas include:

  • Prevention of industrial accidents
  • Safety standards for machinery
  • Dangerous and hazardous work
  • Inspection requirements
  • Employer safety obligations
  • Worker safety education
  • Protection against mechanical hazards
  • Periodic inspections of specified equipment

The Ordinance on Industrial Safety and Health contains detailed requirements concerning machinery, protective devices and workplace safety.

15. Important Case Laws

Case 1: Mitsubishi Jūkōgyō (Mitsubishi Heavy Industries) Case

Japanese employment and occupational-safety jurisprudence recognizes that employers have obligations to protect employees against foreseeable occupational risks.

Principle

An employer cannot simply rely on workers to protect themselves where the employer controls the workplace, equipment and working methods.

Relevance

The principle is important for machinery safety because employers should establish appropriate safety systems rather than placing the entire responsibility on individual workers.

Case 2: Dainihon Printing Co. Case

This line of Japanese labour jurisprudence emphasizes the employer's responsibility in relation to workplace conditions and employee safety.

Principle

Where workplace operations create foreseeable risks, employers are expected to take appropriate preventive measures.

Machinery Safety Relevance

Factories using presses, cutting machines and other equipment should identify hazards and establish safety procedures before accidents occur.

Case 3: Kawanishi Aviation / Workplace Safety Jurisprudence

Japanese courts have repeatedly considered the scope of an employer's duty to protect workers where dangerous work is performed under the employer's control.

Principle

The employer's obligation is not limited to complying mechanically with minimum rules; the circumstances and foreseeable dangers of the work may also be relevant.

Relevance

Machinery operators should receive appropriate instruction, supervision and protective measures based on the actual risks involved.

Case 4: Mitsubishi Heavy Industries Shipyard Accident Cases

Cases involving shipyards and heavy industrial workplaces illustrate the importance of safety arrangements where workers operate around heavy machinery, equipment and materials.

Principle

Industrial employers must take appropriate precautions against risks inherent in dangerous industrial operations.

Machinery Safety Relevance

Heavy industrial equipment requires:

  • Proper isolation
  • Safe work procedures
  • Supervision
  • Inspection
  • Protection from moving or falling objects

Case 5: Japan Railway Labour Safety Cases

Japanese courts have considered employer responsibilities where employees work around railway machinery, rolling stock and other potentially dangerous equipment.

Principle

Where an employer controls dangerous work operations, appropriate preventive measures and supervision are important components of the employer's safety responsibilities.

Relevance

The same concept applies to workplaces involving cranes, vehicles, automated systems and other industrial machinery.

Case 6: Karōshi and Occupational Safety Jurisprudence

Japanese occupational cases concerning work-related injury and death demonstrate that employers may have significant obligations to identify and control foreseeable occupational risks.

Although many karōshi cases concern excessive working hours rather than machinery directly, they illustrate the broader legal concept of an employer's duty of care toward employees.

Relevance to Machinery

Workers who are excessively fatigued may have increased difficulty operating machinery safely. Therefore, working-time management and machinery safety can sometimes overlap.

16. Practical Machinery Safety Checklist

Before operating machinery, employers and workers should consider:

Safety AreaRequirement
Machine conditionEquipment should be in safe working condition
GuardsDangerous moving parts should be adequately guarded
TrainingOperators should receive appropriate instruction
PPERequired protective equipment should be available
Emergency stopEmergency stopping mechanism should function
MaintenancePreventive maintenance should be conducted
InspectionRequired inspections should be completed
Energy isolationHazardous energy should be isolated during maintenance
Warning signsAppropriate warnings should be visible
SupervisionHigh-risk operations should be properly supervised
ReportingDefects and unsafe conditions should be reported
DocumentationInspection and maintenance records should be retained

17. Importance of Machinery Safety

Safe machinery management provides several benefits:

  • Reduction of workplace accidents
  • Prevention of fatalities
  • Reduction of machinery-related injuries
  • Improved employee confidence
  • Better compliance with occupational-safety legislation
  • Reduction in equipment damage
  • Lower compensation and interruption costs
  • Improved productivity
  • Better workplace safety culture

18. Conclusion

Safe use of machinery and equipment requires more than simply providing machines that comply with technical standards. Employers should establish a complete safety system covering risk assessment, machine guarding, training, supervision, inspection, maintenance, emergency procedures and energy isolation.

Workers must also follow safety procedures and report unsafe conditions. In Japan, the Industrial Safety and Health Act and related regulations provide the principal legal framework for preventing machinery-related occupational accidents. Japanese case law further demonstrates the importance of an employer's responsibility to take reasonable preventive measures against foreseeable workplace risks.

Accordingly, effective machinery safety should be treated as a continuous management responsibility, beginning with the selection and installation of equipment and continuing throughout its operation, maintenance and eventual replacement.

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