|Pinnacle Systems, Inc. - Safety Light Curtains, Safety Mat Systems and Ergonomic Palm Buttons|
|Page: Appendix B|
Nonmandatory guidelines for certification/validation of safety systems for presence sensing device initiation of mechanical power presses
This Appendix provides employers, manufacturers, and their representatives, with nonmandatory guidelines for use in developing certification documents. Employers and manufacturers are encouraged to recommend other approaches if there is a potential for improving safety and reducing cost. The guidelines apply to certification/validation activity from design evaluation through the completion of the installation test and the annual recertification/revalidation tests.
A. The certification/validation process should confirm that hazards identified by hazard analysis, (HA), failure mode effect analysis (FMEA), and other system analyses have been eliminated by design or reduced to an acceptable level through the use of appropriate design features, safety devices, warning devices, or special procedures. The certification/validation process should also confirm that residual hazards identified by operational analysis are addressed by warning, labeling safety instructions or other appropriate means.
B. The objective of the certification/validation program is to demonstrate and document that the system satisfies specification and operational requirements for safe operations.
The safety attributes of a certified/validated PSDI safety system are more likely to be maintained if the quality of the system and its parts, components and subsystem is consistently controlled. Each manufacturer supplying parts, components, subsystems, and assemblies needs to maintain the quality of the product, and each employer needs to maintain the system in a non-degraded condition.
A. Certification/validation of hardware design below the system level should be accomplished by test and/or analysis.
B. Analytical methods may be used in lieu of, in combination with, or in support of tests to satisfy specification requirements.
C. Analyses may be used for certification/validation when existing data are available or when test is not feasible.
D. Similarity analysis may be used in lieu of tests where it can be shown that the article is similar in design, manufacturing process, and quality control to another article that was previously certified/validated in accordance with equivalent or more stringent criteria. If previous design, history and application are considered to be similar, but not equal to or more exacting than earlier experiences, the additional or partial certification/validation tests should concentrate on the areas of changed or increased requirements.
The analysis reports should identify: (1) The basis for the analysis; (2) the hardware or software items analyzed; (3) conclusions; (4) safety factors; and (5) limit of the analysis. The assumptions made during the analysis should be clearly stated and a description of the effects of these assumptions on the conclusions and limits should be included.
Certification/validation by similarity analysis reports should identify, in addition to the above, application of the part, component or subsystem for which certification/validation is being sought as well as data from previous usage establishing adequacy of the item. Similarity analysis should not be accepted when the internal and external stresses on the item being certified/validated are not defined.
Usage experience should also include failure data supporting adequacy of the design.
[53 FR 8360, Mar. 14, 1988]