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Machine Guarding
NEP Amputation
WWSC
Virtual Meeting
October 15, 2020
Mary Bauer CIH, CSP
Compliance Assistance Specialist
Eau Claire, WI 54701
715-832-9019
Welcome & Introduction
Mary Bauer Compliance Assistance Specialist (CAS) Eau Claire OSHA Office
CIH: Certified Industrial Hygienist CSP: Certified Safety Professional
20 Years Inspector Over 1000 Inspections
15 Years as CAS
2
History / Background
Obvious Need for Guarding
Standards Incorporated by Reference
1950’s and 1960’s
Industry Requirements Vary
Woodworking
Paper Mills
Mechanical Power Presses
Table O-10
More Automated World
Part 1910 Subpart O –Machinery and Machine Guarding
1910.211 - Definitions.
1910.212 - General requirements for all machines.
1910.213 - Woodworking machinery requirements.
1910.214 - Cooperage machinery. [Reserved]
1910.215 - Abrasive wheel machinery.
1910.216 - Mills and calenders in the rubber and
plastics industries.
1910.217 - Mechanical power presses.
1910.218 - Forging machines.
1910.219 - Mechanical power-transmission
apparatus.
Specific Standards
1910.147: Locked Out OR Safeguarded!!!
Subpart R: Special Industries Sawmills
Bakery
Papermills
Logging
1926.300-.307: Subpart I: Hand Tools
1926.702: Concrete Equipment Guarding
Vertical vs. Horizontal Standards
Section 1910.212 is a general (or (horizontal) standard that applies to all machines not specifically mentioned elsewhere in other sections of Subpart O. Press Brakes Iron Workers Conveyors
Specific (vertical) standards that apply to particular types of machines;1910.213: Woodworking Machines1910.215: Abrasive Wheels1910.216: Calendars & Mills1910.217: Mechanical Power Presses1910.218: Forging Machines
General Industry vs. Construction
Gen Industry Construction
Definitions 1910.211 None
General 1910.212 1926.300
Woodworking 1910.213 1926.304 (Part)
Abrasive Wheel 1910.215 1926.300
Mech Power Transmission
1910.219 1926.307
Top Ten Violations: FY 2019 (with top 5 sections cited)
4) 1910.147 – Lockout/Tagout
• 1910.147(c)(4)(i) (556 violations) – developing, documenting, and utilizing energy control procedures
• 1910.147(c)(6)(i) (383 violations) – periodic inspection of energy control procedure at least annually
• 1910.147(c)(1) (300 violations) – establishing an energy control program
• 1910.147(c)(7)(i) (246 violations) – training on the energy control program
• 1910.147(d) (185 violations) – elements of lockout/tagoutprocedures
Top Ten Violations: FY 2019 (with top 5 sections cited)
9) 1910.212 – Machine Guarding
• 1910.212(a)(1) (1,281 violations) – providing one or more methods of machine guarding
• 1910.212(a)(3)(ii) (458 violations) – point of operation guarding: guarding device
• 1910.212(b) (101 violations) – anchoring fixed machinery
• 1910.212(a)(2) (49 violations) – affixing guards to the machine
• 1910.212(a)(3)(iii) (34 violations) – point of operation guarding: special handtools for placing and removing material
General Machine vs. Point of Operation
vs. Mechanical Power Transmission
Machine guarding. 1910.212(a)(1) One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are-barrier guards, two-hand tripping devices, electronic safety devices, etc.
1910.212(a)(3)(i) Point of operation is the area on a machine where work is actually performed upon the material being processed. 1910.211(a)(1) "Point of operations" means that point at which cutting, shaping, boring, or forming is accomplished upon the stock.
1910.219 Power transmission apparatus: all components of the mechanical system that transmit energy to the part of the machine performing the work. These components include flywheels, pulleys, belts, connecting rods, couplings, cams, spindles, chains, cranks, and gears.
Directives / Ltr Of Interpretation
Machine Specific Directives
Size of Belts: Sewing Machines http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1725
NEP Amputation CPL 03-00-022 https://www.osha.gov/sites/default/files/enforcement/directives/CPL_03-00-022.pdf
Letters of Interpretation: https://www.osha.gov/laws-regs/standardinterpretations/standardnumber/1910
Directives: Press Brakes
Press Brakes CPL 02-01-025 - CPL
2-1.25 - Guidelines for Point of Operation Guarding of Power Press Brakes
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1530
02/14/1997
blah, blah, 4”,blah, blah
Directives:
Press Brake
Exception Safe Guards
ER Demonstrate
Infeasibility
Opinions Vary
History w/o Injuries
Trained Workers (spelled out in directive)
Supervision and Periodic Inspections
Small Quantity Runs
4 hr/mo
Alternative Methods
Hydraulic Press Brake Laser
Transmitter and receiver are mounted on the ram of the press.
Only on Hydraulic Press Brakes
Must be properly installed, (i.e. Mfg.)
OSHA will accept but evaluated on a case-by-case basis.
Interpretations: Vertical Mixer
Therefore, based on these ALJ decisions and FIRMprocedures, the compliance officer must carefully determine if there is employee exposure. The following are some factors that must be taken into consideration when evaluating exposure to a vertical mixer's hazards such as point-of-operation, ingoing nip points, and rotating parts:
How the mixer functions (e.g., visibility of agitator, ability to accidentally switch on);
How worker performs operations (e.g., adding ingredients, scraping the bowl, checking dough for consistency);
Distance worker is from point-of-operation hazard or rotating part -- how close does worker get to hazard during operation;
Tools, clothing, jewelry, or hair of worker that might get caught or fall into mixer;
Type of guarding in place or provided, if any; Any slipping or tripping hazards in the area.
Hazards Associated
Hazard Caught-In / Pulled Into Struck-By Crushing Shearing Entanglement
Outcome / Injury Death Amputation Avulsion Degloving Contusions / Bruising / Cuts Scalping
Application to Real World
1910.212 Everywhere!
1910.213 - Woodworking Cabinet Shops – Everywhere!
Sawmills
1910.215 - Grinders Every Maintenance Shop
1910.216 Banbury: Rubber
Plastics: Blown Film
Application to Real World
1910.217: Mechanical Power Presses Metal Fabrication/Machine
Equipment Mfg.
Window Mfg.
1910.218: Forging Machines Very Limited
Employer Complaints/Excuses Manufactured that way
Purchased that way
Ee didn’t report problem
Ee defeated the safeguard
OSHA’s Response?Employer is Responsible for….
How Do CSHOs Evaluate the
Hazard?
Show Exposure to Hazard
Review ALL Tasks w/ Operator
What is “adequate guarding”?
Table O-10: Vertical Std. 1910.217
LOTO when safeguards removed
Jams, Clearing, Set-up, Cleaning
Allowances for Machines or Industry
Push Sticks for Woodworking
Review Commission
“Section 1910.212(a)(1) is a general machine guarding standard that applies to all machinery not otherwise covered by Subpart O. The guarding required must be provided by a “device” that does not allow reliance upon the skill or attentiveness of employees. It is “intended to eliminate danger from unsafe operating procedures, poor training or employee inadvertence.”
Cincinnati Incorporated, OSHRC Docket No. 00-0955, Final Order Date 10/02/00
• “Section 1910.212(a)(1) is a general machine
guarding standard that applies to all machinery
not otherwise covered by Subpart O. The
guarding required must be provided by a
“device” that does not allow reliance upon
the skill or attentiveness of employees. It is
“intended to eliminate danger from unsafe
operating procedures, poor training or employee
inadvertence.”
Cincinnati Incorporated, OSHRC Docket No. 00-0955, Final Order Date 10/02/00
• “Section 1910.212(a)(1) is a general machine
guarding standard that applies to all machinery
not otherwise covered by Subpart O. The
guarding required must be provided by a
“device” that does not allow reliance upon
the skill or attentiveness of employees. It is
“intended to eliminate danger from unsafe
operating procedures, poor training or employee
inadvertence.”
Cincinnati Incorporated, OSHRC Docket No. 00-0955, Final Order Date 10/02/00
Press Safety Distances
Table O-10
Distance of Opening from Point
of Operation Hazard (inches)
Maximum width of opening
(inches)
1/2 to 1-1/2
1-1/2 to 2-1/2
2-1/2 to 3-1/2
3-1/2 to 5-1/2
5-1/2 to 6-1/2
6-1/2 to 7-1/2
7-1/2 to 12-1/2
12-/12 to 15-1/2
15-1/2 to 17-1/2
17-1/2 to 31-1/2
1/4
3/8
1/2
5/8
3/4
7/8
1-1/4
1-1/2
1-7/8
2-1/8
OSHA vs. ANSI
OSHA GUARD-OPENING SCALE—Part No. KSC-011This folding guard-opening scale is based on Table O-10 of OSHA 29 CFR 1910.217 for mechanical power presses, which shows the distances that guards shall be positioned from the point of operationbased on opening size. It is constructed of durable stainless-steel and has permanent etched markings.
ANSI GUARD-OPENING SCALE—Part No. KSC-075This folding guard-opening scale is based on “A Review of Machine-Guarding Recommendations” by Donald R. Vaillancourt and Stover H. Snook of the Liberty Mutual Research Center for Safety and Health. The ANSI/RIA R15.06 safety standard for industrial robots and robot systems, as well as recently revised ANSI B11–series safety standards for machine tolls, use the guard-opening data from this study. The Canadian power press standard, CSA Z142-02, also uses the data from this study. One side of the scale shows English units; the other side shows metric units. It is constructed of durable stainless-steel and has permanent etched markings.
UL Articulated Finger Probe – Model
ULP04
The UL Articulated Finger Probe is a standard articulated finger as required by Underwriters Laboratories in many of their standards. This new version probe is machined of plastic.
Inspection Protocol
Scope/Purpose:
NEP Amputation:
Any machinery and/or equipment that could cause amputations
SST (Site Specific Targeting):
Wall-to-Wall
Complaints
Conjunction w/ LOTO Review
Inspection Protocol
***We don’t ask Ees to expose themselves for file documentation!!!***
Observe Machine & Operator Several Cycles May need to come back at another time May be off shift operation/shutdown/clean up
Interviews: When, Where, How, Why, How Many…
Document Safeguards, Alternative Methods, and/or Inadequacies: Photos, Measurements, Owner’s Manuals
Inspection Protocol
Familiar w/ Task or Process
Tracking the Tail Pulley: “On the Fly”
Adjustment Nut
UnguardedFluted Conveyor
Citation Issues
1910.219
Group:
(d) Pulley Hazard
(e) Belt Hazard
1910.212 & .217 Point of Operation
1910.212: Side and Back Exposure to Others
1910.217: Operator Exposure
NO REPEATS on .212 if Different Machine
Risk Assessment
Results of the risk assessment provides guidance on safeguarding selection.
Probability of
Occurrence of Harm
Severity of Harm
Catastrophic Serious Moderate Minor
Very Likely High High High Medium
Likely High High Medium Low
Unlikely Medium Medium Low Negligible
Remote Low Low Negligible Negligible
Table 1: Risk Estimation Matrix ANSI B11.TR3 - 2000
Hierarchy of Control
PROTECTIVE MEASURE EXAMPLES
Elimination or
Substitution
•Eliminate human interaction in the process.
•Eliminate pinch points (increase clearance)
•Automated material handling. Etc.
Engineering Controls(Safeguarding/Safeguards)
•Guards – Fixed, Interlocked, Adjustable, Etc.
Interlocks
•Presence Sensing Devices - light curtains,
safety mats, area scanners, etc.
•Two Hand Controls and Trip Devices
Awareness Means•Lights, beacons, and strobes
•Computer Warnings
•Signs and Labels
•Beepers, Horns, and Sirens
Training and Procedures
(Administrative Controls)
•Safe Work Procedures
•Safety Equipment Inspections
•Training
•Lockout/Tagout/Tryout
Personal Protective
Equipment
(PPE)
•Safety glasses/Face Shields
•Ear Plugs
•Gloves
•Protective Footwear
•Respirators
Most Effective
Least Effective
A-U-T-O Barrier Protection
(Around, Under, Through or Over)
Prevent the entry of hands or fingers into the point of operation by reaching through, over, under or around the guard.
Controls or Abatement Methods
Requirements of Safeguards
Prevent contact
Secure
Displacement/damage
Cannot be easily removed
Protect from falling objects
Create no new hazards
Create no interference
Allow safe lubrication
Prevent contact: The safeguard must prevent hands, arms, or any part of a worker's
body or clothing from making contact with dangerous moving parts. A good safeguarding system eliminates the possibility of the operator or other workers placing parts of their bodies near hazardous moving parts.
Secure: Workers should not be able to easily remove or tamper with the
safeguard, because a safeguard that can easily be made ineffective is no safeguard at all. Guards and safety devices should be made of durable material that will withstand the conditions of normal use. They must be firmly secured to the machine.
Protect from falling objects: The safeguard should ensure that no objects can fall into moving
parts. A small tool which is dropped into a cycling machine could easily become a projectile that could strike and injure someone.
Create no new hazards: A safeguard defeats its own purpose if it creates a hazard of
its own such as a shear point, a jagged edge, or an unfinished surface which can cause a laceration. The edges of guards, for instance, should be rolled or blunted in such a way that they eliminate sharp edges.
Create no interference: Any safeguard which impedes a worker from performing the
job quickly and comfortably might soon be overridden or disregarded. Proper safeguarding can actually enhance efficiency since it can relieve the worker's apprehensions about injury.
Allow safe lubrication: If possible, one should be able to lubricate the machine
without removing the safeguards. Locating oil reservoirs outside the guard, with a line leading to the lubrication point, will reduce the need for the operator or maintenance worker to enter the hazardous area.
Controls or Abatement Methods
Methods of Guarding
Guards
Devices
Location/distance
Feed mechanisms
Miscellaneous aids Awareness Barrier
Hand Tools
Jigs/Fixtures
Misc Protective Shields
TWO Basic Safeguarding Methods
1. Guards – 4 types
Guards provide physical barriers that PREVENT ACCESS to the danger areas.
2. Devices -- 7 Types
Devices function by interrupting the machine’s operating cycle to prevent
Workers from reaching or entering the danger area while the machine is cycling.
Controls or Abatement Methods
Guards
Barrier to prevent access to danger
Fixed guards
Interlocks
Adjustable
Self-adjusting
Stock Exit
Stock entering
danger zone
Transparent insert
in front panel
Adjustable but yet secured….
Controls or Abatement Methods
Devices
Presence-Sensing
Photoelectric (Optical)
Radiofrequency (Capacitance)
Electromechanical sensing device
Pullbacks
Restraints
Safety Laser Scanners
Warning and Protected Zones Clearly Marked-The Zones should be clearly marked to give persons in the area a clear indicator of the location of the zones.
The System is Installed Properly- The units should not be more than 12” above the walking surface when mounted horizontally.
Graphics Courtesy of Scientific Technologies, Inc.
Controls or Abatement Methods
Devices
Safety Trip Controls Pressure-Sensitive Body Bar
Safety Trip Rod
Safety Trip Wire Cable
Two-Hand Controls
Two-Hand Trip
Gates Interlocked
Other
This two hand control station was damaged when the operator placed it too close to the press and the upper ram descended on the controls and pinned the operators hand between the ram and the ring guard. The operator was pinned in place for over 20 minutes and lost three fingers and had extensive damage to back and neck.
Two Hand Control/Trip
1910.217(c)(3)(vii)(c)
safety distance (D(s)) formula:
D(s) = 63 inches/second X T(s);
D(s) = minimum safety distance (inches); 63 inches/second=hand speed constant;
T(s) = stopping time of the press
Photo Courtesy of Rockford Systems Inc.
• ANSI B11.19-2003– Ds = K(Ts +Tc +Tr +Tspm) + Dpf
• K – Individual maximum speed• Ts – Machine cycle stop time• Tc – Reaction time of control system• Tr – Reaction time of device detection• Tspm – Performance Monitor stop time
0.9 0.90.6 0.6
0.9
0.990.6 0.84
0.999
0.9
0.6 0.936
If the interlock mechanism has a reliability of 0.9, the reliability of three
interlocks in parallel approaches one. Even if the interlock mechanism
has a degraded reliability of 0.6, the reliability of three in parallel is 0.94.
Control Reliability IncreasesWith Redundancy in Parallel
Mechanical Interlock Devices
Trap Key / Captive Key Systems Principles: Premise that no one key can be in two places at once,
and can be configured to require a predetermined sequence of events takes place to eliminated or reduced hazards to a tolerable level before operators are exposed to them.
Application: Robotic work cells, to prevent the accidental or illegal discharge of processing material, to control access to equipment or machinery while it is in a dangerous state.
Advantages: Can be used in an explosive atmosphere, and provide a higher degree of security and tamper resistance.
Photo Courtesy of Scientific Technologies, Inc.
Training: Not for General Subpart – Required .217
a description and identification of the hazards associated with particular machines
the safeguards themselves, how they provide protection, and the hazards for which they are intended
how to use the safeguards and why how and under what circumstances safeguards can be
removed, and by whom (in most cases, repair or maintenance personnel only)
what to do (e.g., contact the supervisor) if a safeguard is damaged, missing, or unable to provide adequate protection.
This kind of safety training is necessary for new operators and maintenance or setup personnel, when any new or altered safeguards are put in service, or when operators are assigned to a new machine or operation.
Worker Protection
PPE – Not Creating a Hazard
No Loose Hair
No Rings/Jewelry
No Baggy or Loose Clothes
Extreme Care w/ Tool Bags or Belt
What Guarding
Equipment/Method Is Right?
There is no “SILVER BULLET” when it comes to machine guarding.
May require more than one type per process or equipment.
E-Tool
https://www.osha.gov/SLTC/etools/machineguarding/standards.html
Additional Resources
ANSI
B11 Metal Forming
O1.1 Woodworking
ANSI/RIA R15.06 Robotics
NFPA 79: Electrical Standard for Industrial Machinery
Rockford Systems
http://www.rockfordsystems.com
U. S. Safety Standards
ANSI B11.1 2001 Mechanical Power Presses
ANSI B11.2 1995/R2005 Hydraulic Power Presses
ANSI B11.3 2002 Power Press Brakes
ANSI B11.4 2003 Shears
ANSI B11.17 2004 Horizontal Hydraulic Extrusion Presses
ANSI B11.18 1997 Machines for Processing Strip, Sheet, or Plate from Coiled Configuration
ANSI B11.19 2003 Performance Criteria for Safeguarding
ANSI B11.20 2004 Manufacturing Systems/Cells
ANSI/AMT B15.1 2000 Power Transmission Apparatus
ANSI/ASME B19.1 1995/2003 Air Compressor Systems
ANSI/ASME B20.1 2006 Conveyors and Related Equipment
American National Standards Institute (ANSI)
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Wisconsin Compliance Assistance
Specialists
Kelly Bubolz Vacant
U. S. Dept. of Labor - OSHA U. S. Dept. of Labor - OSHA
1648 Tri Park Way 1402 Pankratz St, Suite #114
Appleton, WI 54914 Madison, WI 53704
(920) 734-4521 (608) 733-2822
Bubolz.Kelly@dol.gov
Mary Bauer Vacant
U. S. Dept. Of Labor - OSHA U. S. Dept. of Labor - OSHA
1310 W. Clairemont Ave 310 W. Wisconsin Ave
Eau Claire, WI 54701 Milwaukee, WI 53203
(715) 832-9019 (414) 297-3315
Bauer.mary@dol.gov
On-Site Consultation Program
No cost to employers
Separate from enforcementand confidential
Identifies workplace hazards
Advice on compliance with OSHA standards
Helps employers establish safety and health programs
26,000 visits annually to small employers
Help for Small Businesses: OSHA’s On-Site Consultation Program
On-Site Consultation Program
On-Site Consultation is OSHA's preeminent compliance assistance program for small employers. In all 50 States and most Territories.
Services• Hazard identification and correction• Assistance in Safety and Health Program development
Benefits• No-cost and confidential• Exemption from OSHA's programmed inspections• Training and technical assistance available
http://www.slh.wisc.edu/occupational/wiscon/
www.osha.gov/dcsp/smallbusiness/consult.html
Disclaimer
This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics or hazards, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.
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