Certification of safety systems

The third-party validation must be done by an OSHA-recognized independent validation organization; the Appendix requires the validator to be recognized by OSHA under the criteria in Appendix C. See 1910.217AppA which explains that certification/validation "shall utilize an independent third-party validation organization recognized by OSHA in accordance with the requirements specified in appendix C of this section." Also consult 1910.217AppC for the recognition requirements and processes.

Yes — the manufacturer, an employer, or their representative may initiate the design certification; an employer who assembles a PSDI system is treated as a manufacturer for these purposes. Appendix A says the design certification "may be initiated by manufacturers, employers, and/or their representatives" and explicitly states an employer who assembles a PSDI safety system is a manufacturer for the standard's purposes; see 1910.217AppA.

The process has a two-stage approach: (1) the manufacturer certifies the design against 1910.217(a)–(h) and Appendix A, and (2) an OSHA-recognized third-party validation organization validates the manufacturer's certification by reviewing design/test data and performing additional reviews or tests. Appendix A describes this two-stage design certification/validation process; see 1910.217AppA.

The design certification must identify all major parts, components and subsystems by part or serial number and manufacturer to establish the system configuration. Appendix A requires that "The major parts, components and subsystems used shall be defined by part number or serial number, as appropriate, and by manufacturer to establish the configuration of the system"; see 1910.217AppA.

You must evaluate and document environmental limits (temperature, humidity, vibration, fluid compatibility) and design limits (power requirements, transients, material compatibility, signal sensitivity, electromagnetic tolerance, component life, etc.). Appendix A lists these areas explicitly as required evaluation topics; see 1910.217AppA.

An employer must inspect and recertify the installation annually, or sooner if hardware is changed, operating conditions change, or a critical component failure occurs; Appendix A specifies the PSDI system remains under certification for the shorter of one year or until such a change occurs. See 1910.217AppA for the annual recertification and change triggers.

Recertification is not required for operational changes such as die changes or press relocations that do not involve disassembly or revision to the safety system; Appendix A notes such relocations without safety-system revision do not trigger recertification. See 1910.217AppA.

The manufacturer must certify that identified parts and subsystems can withstand the functional and operational environments of the PSDI safety system. Appendix A says the identified parts, components and subsystems "shall be certified by the manufacturer to be able to withstand the functional and operational environments of the PSDI safety system"; see 1910.217AppA.

The validator reviews that the safety system was design certified/validated, checks the employer's installation, operation, maintenance and training records, confirms installation drawings, and performs additional tests/reviews it deems necessary. Appendix A requires the third-party validation organization to validate the employer's certifications and perform any additional tests or reviews it believes necessary; see 1910.217AppA.

It means certification/validation must consider the complete interaction of the press, control logic, safety devices, operator behavior, and surrounding environment to ensure compliance with 1910.217(a)–(h) and Appendix A—evaluating them together rather than individually. Appendix A states the certification/validation "shall consider the press, controls, safeguards, operator, and environment as an integrated system"; see 1910.217AppA.

The PSDI safety system must sustain a single failure or single operating error without causing injury; acceptable design features include eliminating single-failure hazards, or using redundancy, comparison and diagnostic checking for critical items. Appendix A requires the system to "have the ability to sustain a single failure or a single operating error and not cause injury" and lists acceptable design features and redundancy; see 1910.217AppA.

Reaction time is the time from signal initiation to completion of the function being measured; tests must follow Appendix A definitions and use instruments calibrated to 0.001 second accuracy and a test-signal initiation error under 0.5% of the measured reaction time. Appendix A provides specific definitions for reaction time and measurement requirements and requires that "The instrument used to measure reaction time shall be calibrated to be accurate to within 0.001 second"; see 1910.217AppA and 1910.217(h).

You must compute the average stopping time Ts as the arithmetic mean of at least 25 stops for each stop-angle initiation measured under three brake/clutch conditions: unused, 50% worn, and 90% worn (simulated per the brake manufacturer). Appendix A requires at least 25 stops per condition and refers specifically to the compliance procedures in 1910.217AppA and the requirement in 1910.217(h)(2)(ii).

Appendix A requires documenting the manufacturer's recommended minimum lining depth, simulating or estimating wear per the brake maker's guidance, correlating degradation to stopping-time performance, and creating a marked scale indicating allowable overtravel and when brake adjustment/replacement is required. See 1910.217AppA and the compliance detail tied to 1910.217(h)(2)(ii).

A full new design certification is needed for substantial modifications that change the safety of the system; minor modifications that do not affect safety may be made without revalidation if the manufacturer and validator agree by similarity analysis. Appendix A explains that new design certification applies to new designs or substantial modifications, while similarity analysis may be acceptable for equivalent modifications; see 1910.217AppA.

The manufacturer must submit documentation demonstrating full compliance with 1910.217(a)–(h) and Appendix A by analysis, tests, or both—covering design, component specs, environmental limits, test data, and results demonstrating single-failure tolerance and performance. Appendix A requires the submission of necessary documentation for the validator to demonstrate compliance; see 1910.217AppA.

No — design certification testing for a new safety system applies once to the design and is applicable to all identical safety systems; individual systems of the same design do not require repeat full certification testing unless modifications are made. Appendix A states new design certification "would entail a single certification/validation which would be applicable to all identical safety systems"; see 1910.217AppA.

The employer must certify the PSDI system has been design certified/validated, that installation meets the manufacturer's operational/environmental requirements, that installation drawings are accurate, and that the installation complies with 1910.217(a)–(h) and Appendix A. Appendix A outlines these employer certification obligations for installation; see 1910.217AppA.

The validator may review the manufacturer's certification, the employer's installation documentation and tests, observe operation, inspect training and maintenance records, and perform any additional tests or reviews it believes are necessary to validate compliance. Appendix A authorizes the third-party validation organization to perform additional reviews and tests as it deems appropriate; see 1910.217AppA.

Design certification must evaluate electromagnetic tolerance to both specific operational wavelengths and externally generated wavelengths and document that components can tolerate expected electromagnetic environments. Appendix A lists electromagnetic tolerance as a required design evaluation area; see 1910.217AppA.

Acceptable demonstrations include designing out single-failure hazards, providing redundancy, performing comparison/diagnostic checks on critical items, and selecting parts rated for operational/environmental stresses—documented via analysis and testing. Appendix A explains acceptable design features and requires the manufacturer to evaluate and certify the single-failure tolerance; see 1910.217AppA.

Reaction-time instruments must be calibrated accurate to 0.001 second, and the test-signal generation must permit initiation-time error under 0.5% of the measured reaction time. Appendix A sets these precise measurement and calibration criteria for reaction-time testing; see 1910.217AppA and 1910.217(h).

If a critical component failure occurs, the PSDI safety system must be re-certified/re-validated before further use; Appendix A requires recertification/revalidation after a failure of a critical component (or other covered changes) rather than waiting for the annual cycle. See 1910.217AppA.

Minor modifications that do not affect system safety may be made by the manufacturer without revalidation, provided the manufacturer documents them and the third-party validation organization agrees they are minor/equivalent by similarity analysis; see 1910.217AppA.

Yes — the certification/validation must evaluate repeatability of measured parameters, operational life in cycles/hours, and sensitivity to signal acquisition to ensure components won't inadvertently initiate a press stroke; Appendix A lists these among required design-limit evaluations. See 1910.217AppA.

The manufacturer must submit the test specifications, procedures, and supporting technical analyses to the validation organization before testing and make test results and designs available upon request.

• The requirement to submit the test specification and procedure for review and validation prior to the test is in 1910.217AppA.
• Manufacturers must also provide design analyses such as Hazard Analysis, Failure Mode and Effects Analysis (FMEA), Stress Analysis, Component and Material Selection Analysis, and other analyses identified in 1910.217AppA.
• The validation organization must be allowed to witness at least one set of each required test; tests and results must be made available on request to the validation organization, per 1910.217AppA.

Each reaction time used to calculate the Safety Distance (including the brake monitor setting) must be documented in separate reaction time tests with specified tolerance bands to prevent tolerance build‑up from making the safety distance unsafe.

• The appendix requires that "each reaction time required to calculate the Safety Distance, including the brake monitor setting, shall be documented in separate reaction time tests" and that tests specify an acceptable tolerance band; see 1910.217AppA.
• An integrated test of the fully equipped press operating in PSDI mode must be conducted to establish the total system reaction time, and adjustable brakes must be properly set before testing, per 1910.217AppA.
• Use the documented reaction times and tolerances when setting the brake monitor as required under 1910.217(h)(5)(iii) and the safety distance rules in 1910.217(h)(9)(v).

Before the brake test, employers or manufacturers must visually inspect springs and spring housings/rods to ensure there is no damage that would degrade structural integrity and verify springs are not interleaving; any broken or unserviceable springs must be replaced before testing.

• The appendix requires a visual check that the spring housing or rod does not show damage sufficient to degrade structural integrity and that springs do not show a tendency to interleave, per 1910.217AppA and 1910.217(h)(2)(iii).
• Any detected broken or unserviceable springs must be replaced before the brake stopping‑time test; the test is successful only if stopping time remains within limits set in 1910.217(h)(9)(v).

Brake system tests must be witnessed by a representative of the OSHA‑recognized third‑party validation organization, and the test specifications and procedures must be submitted for review before testing.

• The appendix states the test specification and procedure shall be submitted to the validation organization for review and validation prior to the test, and the validation organization representative shall witness at least one set of tests; see 1910.217AppA and 1910.217(h)(2)(ii).
• Integrated press tests in PSDI mode must be conducted to establish total system reaction time as part of these brake system evaluations, per 1910.217AppA.

Manufacturers must test electrical/electronic subsystems (including boards/cards) for ambient temperature range, extreme humidity, vibration, electromagnetic interference, and power supply variations using tests compliant with the National Electrical Code.

• Appendix A requires that subsystems be tested for: ambient temperature variation from −20 °C to +50 °C; ambient relative humidity of 99%; vibration of 45G for one millisecond per stroke when mounted on the press frame; electromagnetic interference at wavelengths used for the sensing field and power‑line frequencies; and electrical power supply variations of ±15 percent; see 1910.217AppA and 1910.217(h)(7).
• The manufacturer must specify test procedures based on existing consensus tests in compliance with the National Electrical Code, per 1910.217AppA.

The manufacturer must design and document a test that demonstrates the presence‑sensing device meets the prescribed minimum object sensitivity and make those test specifications and procedures available to the validation organization.

• Appendix A specifically requires the manufacturer to design a test demonstrating the minimum object sensitivity and to provide the test specs and procedures upon request to the validation organization; see 1910.217AppA and 1910.217(h)(9)(iv).
• Keep records of the test method, pass/fail criteria, measurement tools, and any calibration data so the validation organization can confirm reproducibility and compliance, per 1910.217AppA.

Manufacturers must design tests that establish the allowable hand tool extension diameters and document the range of object diameters that produce single‑ and double‑break responses; the test specs and procedures must be available to the validation organization.

• Appendix A requires manufacturers to design tests to determine hand tool extension diameters allowed for variations in minimum object sensitivity response and to document which object diameters cause single and double break conditions, per 1910.217AppA and 1910.217(h)(9)(x).
• Provide clear pass/fail criteria and measurement methods so the validation organization can review and validate the manufacturer's conclusions, as required by 1910.217AppA.

Integrated tests must demonstrate compliance with the multiple PSDI performance and reliability requirements listed in the appendix—specifically the subsections of 1910.217(h) enumerated in the appendix—and the test specifications and procedures must be available to the validation organization.

• Appendix A directs the manufacturer to design integrated tests to demonstrate compliance with the listed requirements in 1910.217(h), and the integrated test specifications and procedures must be made available to the validation organization; see 1910.217AppA.
• The integrated tests should cover the items identified in Appendix A, including many subsections of 1910.217(h), so the validator can confirm full‑system performance under realistic conditions.

Manufacturers must submit technical analyses such as Hazard Analysis, Failure Mode and Effect Analysis (FMEA), Stress Analysis, Component and Material Selection Analysis, fluid compatibility, and any other analyses necessary to show compliance with the specified subsections of 1910.217(h).

• Appendix A lists the required analyses and ties them to the specific regulatory subsections they support (for example, analyses for 1910.217(h)(8)(i) and (ii) and many of the 1910.217(h)(6) items); see 1910.217AppA.
• These analyses support validation of design choices, component selection, environmental suitability, failure modes, and risk mitigation measures required by the standard, as described in 1910.217AppA.

Test results from development testing may be used, provided they yield the engineering data needed to demonstrate that hardware and software meet specifications and that manufacturing and maintenance processes are supported by the data.

• Appendix A explicitly allows test results obtained from development testing to be used for certification/validation if they provide the engineering data necessary to establish confidence in hardware/software performance, quality control, and production processes; see 1910.217AppA.
• Make sure test reports include methods, instrumentation, acceptance criteria, repeatability data, and traceability so the third‑party validation organization can rely on the results, as called for in 1910.217AppA.

A PSDI safety system must be recertified/revalidated when hardware is significantly changed, when operational conditions change materially, after a significant component failure or change affecting safety, or at least once every year.

• Appendix A requires recertification/revalidation the earlier of: each time hardware is significantly changed/modified/refurbished; each time operational conditions are significantly changed (environmental, application, or facility changes); when a failure of a significant component has occurred or a change that may affect safety is made; or when one year has elapsed since the last certification/revalidation—see 1910.217AppA.
• Treat routine die changes or press relocations that do not revise the safety system as exclusions, but anything that affects the PSDI safety system itself triggers revalidation per 1910.217AppA.

The employer must evaluate and test the PSDI installation, submit supporting documentation to the validation organization, and demonstrate inspection, adjustments, and review of prior certification/validation reports to show the system remains compliant.

• Appendix A requires the documentation to include a thorough inspection of the entire press and PSDI safety system to verify no unauthorized changes, demonstrations that necessary adjustments (such as brake monitor setting changes) have been made and recorded, and review of prior design and installation reports to detect degradation and show corrective actions were taken; see 1910.217AppA.
• The employer must then submit these documents to the OSHA‑recognized third‑party validation organization for review and revalidation, per 1910.217AppA.

The employer must evaluate and test the PSDI installation, submit supporting documentation to the OSHA‑recognized third‑party validation organization, and certify that the installation meets all applicable requirements; the validation organization shall then test or review those submissions and, if satisfied, validate the certification.

• Appendix A states the employer shall evaluate and test the PSDI system installation, submit necessary documentation, and certify compliance with 1910.217(a) through (h); see 1910.217AppA.
• The OSHA‑recognized validation organization must conduct tests and/or review the employer's installation tests and documentation and validate the employer's certification if it determines the installation is in full conformance, per 1910.217AppA.

A representative of the OSHA‑recognized third‑party validation organization must witness at least one set of each required test; manufacturers must also make test specifications, procedures, and results available upon request.

• Appendix A requires that the validation organization representative witness at least one set of tests and that manufacturer‑designed tests be made available upon request to the validation organization, which shall witness at least one set of each test; see 1910.217AppA.
• This applies to individual component tests, subsystem tests, and integrated system tests so the validator can confirm test execution and results, per 1910.217AppA.

If stopping time exceeds the brake monitor setting limit, the test is unsuccessful and the cause must be investigated; you must check springs for damage and proper function and correct any defects before retesting.

• Appendix A states that when press stopping time increases beyond the brake monitor setting limit defined in 1910.217(h)(5)(iii), the test is unsuccessful and the cause of excessive stopping time must be investigated, including verifying that springs are not broken and are functioning properly; see 1910.217AppA.
• Replace broken or unserviceable springs and retest; the stopping time must then meet the safety distance setting limits in 1910.217(h)(9)(v).

Manufacturers must test and analyze components and subsystems identified in 1910.217(h)(6), including mechanical, electrical, control, sensing, and braking elements, to demonstrate they meet reliability, life, stress, and failure‑mode requirements listed in the appendix.

• Appendix A requires manufacturers to design tests and make test results available for the many subsections of 1910.217(h)(6), covering items such as life/stress testing, environmental durability, and functional safety for components including brakes, sensors, and control electronics; see 1910.217AppA.
• The validation organization should be able to review the Failure Mode and Effects Analysis, stress analyses, and test reports that demonstrate the components’ behavior under foreseeable faults, as required in 1910.217AppA.

Manufacturers must make test specifications, procedures, and results available upon request to the validation organization so the validator can review methods, witness tests, and confirm the PSDI system meets performance and safety requirements.

• Appendix A repeatedly requires that test specifications and procedures be submitted to or be made available to the validation organization for review and validation and that the validation organization witness at least one set of tests; see 1910.217AppA.
• Providing these documents ensures transparency of methods, repeatability of results, and allows the third‑party validator to determine whether the design and testing sufficiently demonstrate compliance with 1910.217(h) requirements, per 1910.217AppA.

If the third‑party validation organization determines the PSDI safety system fully complies with 29 CFR 1910.217(a) through (h) and the appendix, it will validate the manufacturer's certification; otherwise it may require additional tests or documentation.

• Appendix A states that after review of all documentation, tests, and analyses, the OSHA‑recognized third‑party validation organization shall validate the manufacturer's certification if it determines the PSDI system is in full compliance with 1910.217(a)–(h) and the appendix; see 1910.217AppA.
• If the validator is not satisfied, it may request additional tests or information until it can make a compliance determination, per 1910.217AppA.

No—an employer must evaluate and test the installation and submit documentation and certification to an OSHA‑recognized third‑party validation organization, which must then review or test and validate the employer's certification.

• Appendix A requires the employer to evaluate and test the PSDI installation and certify compliance, but it also requires the OSHA‑recognized third‑party validation organization to conduct tests and/or review the employer's installation tests and documentation and validate the employer's certification if in full conformance, per 1910.217AppA.
• The third‑party validation is a required independent step before final validation of the installation, according to 1910.217AppA.

The third‑party validation organization must review the employer’s recertification documentation and, if satisfied that the PSDI system remains in full conformance, revalidate the employer’s recertification; otherwise it may require additional corrective action or testing.

• Appendix A requires the OSHA‑recognized third‑party validation organization to conduct tests or review and evaluate the employer's recertification documentation and revalidate the employer's recertification if it determines the system is in full conformance with 1910.217(a)–(h) and the appendix; see 1910.217AppA.
• Employers must provide evidence of inspections, adjustments, and reviews of prior reports to demonstrate no degradation to an unsafe condition, per 1910.217AppA.