Upcoming Regulatory Changes on Machine Safety

by Mar 26, 2024Machine Safety

The Regulation respecting occupational health and safety (RSST) sets out the minimum requirements for ensuring the health and safety of workers. More specifically, Division XXI of the Regulation concerns the safety of machines used in establishments in Québec. The primary objective of the amendments that will be made is to protect the health and safety of workers using these machines.

Everyone, from machine manufacturers and those who supply them to operators and those who offer services related to machine safety, is affected by the regulatory changes.

Objectives of the Changes

First, the CNESST explains the three main orientations of the draft Regulation:

  1. Harmonization with Canadian and international standardization: the standard will now be the same for everyone;
  2. Encouragement of workplaces to acquire machines designed in accordance with the standards: acquiring a machine designed and manufactured in accordance with the standards is a guarantee of effective safety because a manufacturer has more leeway than a user; and,
  3. Delineation of the involvement of engineers: Under the Engineers Act, works on industrial equipment to ensure worker safety fall within a scope of practice reserved for the engineer. The draft regulation simply states that an engineer must be involved when a modification has an impact on worker safety. The engineer must then certify that the modification is safe.

Compliance of a Machine

A machine designed and manufactured to a specific standard, e.g., ISO Type C, will be considered compliant with the RSST provided that the manufacturer provides a declaration of compliance. Otherwise, the current process of a risk analysis carried out by an engineer must be followed to demonstrate compliance of a machine with the relevant sections of the Regulation.

For existing equipment, any modification “which may have an impact on the safety of workers” must be made by or under the supervision of an engineer. The means of protection must be chosen by applying a recognised risk assessment and reduction methodology. Examples include CSA Z432 and ISO 12100. The engineer must then certify the compliance of the modification with the RSST.

Management of Residual Risk

Section 183 of the Regulation, on equivalent safety measures to be put in place when the installation of a means of protection will prevent the machine from performing its intended function, is amended in the draft Regulation. It will no longer refer only to “equivalent safety measures” but to the management of residual risks. It is specified that residual risks must be identified and communicated and that risk reduction measures include work procedures or methods, training, and the necessary personal protective equipment.

Manufacturer’s Manual

A new section particularly concerns manufacturers, who will now have to provide an instruction manual which must include in particular:

  • A detailed description of the machine, its operating parts, its accessories, its means of protection, including where appropriate, the characteristics of each safety function, in particular the parameters relating to reliability, operating limits, indicators, and warning signals;
  • Instructions for adjustments and settings of the machine that affect the health and safety of workers, where applicable;
  • A description of the personal protective equipment recommended to be worn when using the machine, if any, including the information and training necessary for the use of such equipment;
  • The nature and frequency of inspections of safety functions, if any;
  • The residual risks.

Specific Control Mode

The draft Regulation amends the current Section 189, which deals with specific control modes for interventions requiring the operation of hazardous components when guards have been removed, for example. The current version gives two possibilities:

  • Either the control is a maintained action control, e.g., enabling device, two-hand control);
  • Or the moving parts operate at reduced speed, reduced effort, jerky feed, etc.

The draft Regulation requires that these two conditions be met simultaneously. As before, the specific control mode, once selected, must render any other control mode inoperative. A fourth condition is added in the draft Regulation: a voluntary or involuntary action on the machine’s sensors triggers a function presenting a risk to the health and safety of workers.

Reliability of the Safety-Related Control System

The draft Regulation introduces the notion of reliability of the control system. Without citing a standard as a reference, e.g., ISO 13845, the new text nevertheless has the merit of addressing this fundamental notion in machine safety: ensuring that a safety function will play its role when called upon by respecting certain basic principles of good engineering practice. Among other things, there is mention of redundancy and self-monitoring.


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Intervention Prévention Inc.

Intervention Prévention œuvre dans le domaine de la sécurité au travail en offrant des services spécialisés répondant aux normes CSA Z462 – Sécurité électrique en milieu de travail, CSA Z460 – Maîtrise des énergies dangereuses : Cadenassage et autres méthodes, et CSA Z432 – Protection des machines. Nos domaines d’expertise sont donc reliés au cadenassage, à la sécurité électrique et à la sécurité machine. La satisfaction de nos clients est le gage de notre compétence


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