Kyle Malec

Machine Guarding Program

Tech 436

4/26/14

1.0 Scope, Purpose & Application1.1 Scope

The scope of this safety program is to enforce the mandatory use of machine guards while working on machines that can cause injuries to those operating and around the operation.

1.2 PurposeThe purpose of this safety program is to comply with the Occupational Safety and Health Administration’s Machine Guarding standard, 29 CFR 1910.212. This will inform employees operating on machines that what type of guards are required while working, as well as, how they work to prevent serious injuries to those working with or around the machine. The goal of this safety plan is to minimize the injuries sustained while operating machines, such as sheering and cutting machines, which are present at DIMCO, and are an important part of their everyday activities. It is important to maintain these guards so they are able to protect to a specific situation without failure.

1.3 ApplicationThis procedure applies to all employees at DIMCO while operating a machine that requires a machining guard. Any employee operating a machine that requires a guard must be trained to use that specific guard, as well as, the machine itself.

2.0 DefinitionsPoint of operation- The point at which cutting, shaping, or forming is accomplished upon the stock and shall include such other points as may offer a hazard to the operator in inserting or manipulating the stock in the operation of the machine.

Feeding- The process of placing or removing material within or from the point of operation.

Guard- A barrier that prevents entry of the operator’s hands or fingers into the point of operation.

Authorized person- One whom the authority and responsibility to perform a specific assignment has been given by an employer.

3.0 Management Leadership & Employee Participation3.1 Management Leadership

3.1.1 Occupational Health and Safety Management System

Managers and supervisors have the right and duty to implement any sort of machine guards or machine guarding standards when necessary. All employees must follow the procedures that are covered and reviewed.

3.1.2 PolicyAll employees in DIMCO, that are properly trained to operate machines with that require machine guards, shall abide all rules, guidelines, and specific procedures that are set forth when operating such machines at all times.

3.1.3 Responsibility and AuthorityThe manager or supervisor is responsible for making sure their employees are safely operating machines that have the risk of injury. They also need to make sure that when guarding is required, that it, in fact, is being used and used correctly.

3.2 Employee ParticipationEmployees are responsible to have knowledge on when and where guards are required while operating a machine. If there is a lack of guard on a machine, and there should be one present, it is the job of the employee to cease any operations on that specific machine and inform the manager or supervisor of that hazard. Employees should also alert managers or supervisors on other employees not following the set procedures putting themselves or other employees at risk of injury.

4.0 Planning4.1 Initial and Ongoing Reviews

The manager or supervisor must conduct a review of machines (cutting and sheering) requiring guards and determine if what is currently being used is meeting the requirements of the specific standards. In order to protect the machine operator, safeguards must meet minimum general requirements. All guards must prevent any type of contact between the operator and a moving part of a machine, it must be secure, meaning that none one can remove or tamper with the guard, protect from falling objects in a sense if something outside of the operation falls and is turned into a projectile that can injure other employees, the guard shouldn’t create any new hazards, the guard shouldn’t interfere with the work being done, and the employee should be able to lubricate the machine without removing the safeguards. After the correct guards implemented, it is the job of the manager or supervisor to continue reviewing the machines to see if any defections are arising because of use, correct or incorrect. Along with the guards themselves, should be visual guides and instructions on how to operate these guards so anyone can understand how to use them.

4.2 Assessment and PrioritizationThere should be an assessment done to which will determine what types of risks come from machines without guards and evaluate how serious each outcome is. The seriousness and type of risks should be visible to employees working on all machines that pose a risk for injury. Having this will remind the operator the consequences of their actions if they choose

not to follow the required rules. The manager or supervisor also needs to look a previous instance’s where injuries resulted from either operator error and/or a guard failure. From that information, they could determine a plan of action to make sure this specific accident does not happen again. There are four steps to determine if a machine needs a guarding measure. First is to recognize a hazard by identifying hazardous actions and motions. Next, you analyze the workplace and prioritize safeguarding efforts based on the most predictable injuries, the probability, and available resources. Third, you develop and implement a systematic safeguarding program that includes identifying safeguarding methods, proper selection, and correct installation. Finally, you need to ensure the use of safeguarding and reinforce the program through training, education, and enforcement.

4.3 ObjectivesObjectives that can be created surrounding machine guarding are insuring that all guards are used to their full specification and entirety. All objectives that are agreed upon by both managers/supervisors and employees, shall be written down and be able to be accessed at all possible times, working hours or not. Objectives that are set in stone should be of most concern to the safety of the employees. Risks that are not immediate to the endangerment of an employee should be farther down on the list of objectives.

4.4 Implementation Plans and Allocation of ResourcesAfter the risks are identified and documented, it is important to follow through with a plan of action to implement the changes that need to be made. When the new or repaired guards are ready to be fully functional, all employees, as well as management, need to be trained on what it is supposed to protect, how to enable it to start protecting, and why it is important to have this type of protection. If an immediate fix is not available, then inform all authorized operators, as well as unauthorized ones too, that no one is permitted to use that machine under any circumstances.

5.0 Implementation & Operation5.1 OHSMS Operational Elements

5.1.1 Risk AssessmentDIMCO shall establish and implement a risk assessment process appropriate to be nature of hazards and level of risk. The machines that will be assessed in this program will include shearing and cutting machines. Shearing action involves applying power to a slide or knife in order to trim or shear metal or other materials. A hazard occurs at the point of operation where stock is actually inserted, held, and withdrawn. Examples of machines used for shearing operations are mechanically, hydraulically, or pneumatically power shears. Shearing hazards include the crushing or tearing of body parts at the point where materials are inserted, held, or withdrawn. Cutting action may involve rotating, reciprocating, or transverse motions. The danger of cutting action exists at the point of operation where finger, arm and body injuries can occur

and where flying chips or scrap material can strike the head, particularly in the area of the eyes or face. Such hazards are present at the point of operation in cutting metal and other materials. Some examples of machines with cutting hazards include band-saws, circular saws, boring and drilling machines, turning machines (lathes), or milling machines. Cutting machines are common in industries, and present at DIMCO. Cutting hazards occur when your fingers, hands, and other body parts are exposed to cutting actions, or when flying chips or scrap metal can strike your head, face, or eyes. After determining the risks, it is easier to implement the appropriate controls to minimize or eliminate to chance of any injuries occurring while operating either of these machines.

5.1.2 Hierarchy or ControlsDIMCO shall establish a process for achieving feasible risk reduction based upon the following preferred order or controls: elimination; substitution or less hazardous materials, process, operations or equipment; engineering controls; warnings; administrative controls; and personal protective equipment. For a shearing machine, safety devices that will help prevent injury include: a flywheel guard, an emergency stop switch, a guard protecting against hold down and shear, and side-and-top capped pedal controls. Safety measures for a cutting machine, like band saws, chop saws, and miter saws are mainly blade guards. In terms of substitutions, there shouldn’t be any substitutes to the correct and required guards for each specific machine. If the required guard is not available when the time of operation has come, no one will operate that machine until the required guard is in place and fully functional. If there are other machines that have the correct guards in place, and can do the same job, or is in fact the same machine, use the alternative machine rather than risk injury using a hazardous one. Engineering controls are the redesigning equipment, tools, work organization and workplaces to reduce a workers exposure to factors that can cause injury. There are engineering controls that can be implemented to both, cutting and shearing machines. For cutting machines, like saws, there could be a blade guard attached to prevent the operator from getting fingers, hands, or arms getting caught in the blade. You can also install a shield to protect the face and eyes from flying chips. For shearing machines, controls that can be added are a flywheel guard, an emergency stop switch, a guard protecting against hold down and shear, and side-and-top capped pedal controls. Emergency stopping switches are in place just in case something gets caught in the process, like outside objects or body parts. The switch should be within the reach of the operating area and should be able to be reached if the operator gets caught in the machine. Side-and-top capped pedal controls are used so that the operator has complete control of the job at hand to be in complete control. Warnings need to be written where the employees can see them so they know what the risks are of the machine and why it is important to use the guards available and mandatory to use. Administrative controls consist of additional relief workers,

exercise breaks and rotation of workers. These types of controls are normally used in conjunction with other controls that more directly prevent or control exposure to the hazard. Workers can start making mental errors when working for too long, which can increase the risk of injuries. Rotating workers also reduced the risk of injuries of doing a job over and over again, which can get boring and cause employees to lose their concentration and make a mistake. Personal protective equipment could be useful and should be mandatory when operating these machines. Flying chips from shearing machines and saws could hit the face or eyes of the operator or those around the machine. Safety goggles or a face shield would completely eliminate this hazard.

5.1.3 Design Review and Management of ChangeDIMCO shall establish a process to identify, and take appropriate steps to prevent or otherwise control hazards at the design and redesign stages, and for situations requiring management of change to reduce potential risks to an acceptable level. Management should identify the tasks done on each machine and see ways that could cause the operator to injure themselves. They also need to identify types of human errors than can arise in different situations. All measures taken must be in compliance with the Occupational Safety and Health Administration’s Machine Guarding standard, 29 CFR 1910.212. All changes or implementations must meet these codes or risk accidents and financial burdens. It is important to get the point across to your employees so they will understand why changes are being made, and to understand how the new guards work. Ways to get the point across include educating on why guards do what they do, and why they do them, as well as hand on training. Hands on training is important because its gets the employee to understand the motions in the process and know where body parts should and shouldn’t be. Employees should speak up if what management id trying to teach isn’t getting through to them, they could be left with a lack of knowledge of how things are supposed to work.

5.1.4 ProcurementDIMCO shall establish an implement processes to identify and evaluate the potential health and safety risks associated with raw materials and other goods and related services, create requirements for supplies, equipment, raw materials, and other goods and related services, and ensure purchased products, raw materials, and other goods and related services conform to the organizations health and safety requirements. All materials to be worked on must be of the best condition, or processed beforehand to meet the requirements of DIMCO to avoid malfunctions while working with these materials.

5.1.5 ContractorsDIMCO should create provisions that include contractor health and safety performance criteria. Contractors are responsible to comply with this plan and should be provided the proper training needed to operate the machines they

are hired to use. All contractors should be aware of all information current employees possess through hands on training and classroom training courses.

5.1.6 Emergency PreparednessDIMCO must identify, prevent, prepare for and/or respond to emergencies. Injuries sustained from shearing and cutting machines may not be life threatening when they first occur, but over time, the chance greatly increases. All employees of DIMCO will be required to know where all first aid kits are and how to treat various forms of injuries that can result from these machines. Any injuries sustained that can be treated immediately should be as soon as possible and when it is taken care of, the manager or supervisor should be informed of the situation requires more medical attention. In cases of much serious injury, outside medical attention should be sought after. Employees need to know where the closest phone is to where their current location is to call for medical attention. All employees should call 911 for emergencies. If there are no phones on the working floor, there needs to be a radio system in place to inform a manager or supervisor on the current situation and have them determine on the next plan of action.

5.2 Education, Training, Awareness and CompetenceDIMCO is responsible for training their employees so they are able to operate machines in a proper and safe manner. Topics to be trained on are: hazards associated with particular machines, how the safeguards provide protection and the hazards for which they are intended, how and why to use safeguards, how and when safeguards can be removed and by whom, and if a safeguard is damaged, missing, or unable to provide adequate protection.

5.3 CommunicationDIMCO is to institute processes to communicate information about the progress being made on its implementation plan, ensure prompt reporting of incidents, hazards and risks, promote employee involvement so they can make recommendations on hazards and risks. There should be a system implemented so communicate between employee and management to distribute important information regarding injuries. Radios are an efficient way to communicate information quickly and regardless of the location on the property.

5.4 Document and Record Control ProcessDocuments regarding machine operation and guarding much be available by anyone at all times. Documents should be updated as needed, legibly, adequately protect against damages or loss, and retained as necessary. Proper documentation of the risks that are present while operating shall be created, or updated if some already exist. All records should be neatly organized so in the event of an emergency, anyone trying to access information will have no trouble finding what is sought after.

6.0 Evaluation & Corrective Action6.1 Monitoring, Measurement, and Assessment

This program will be reviewed annually and when changes are to be implemented. The supervisor or manager is the only person able to make and authorize these changes. When the time comes for review, factors that will be covered are how well are current guards holding up, where can guards be implemented, and which guards that are already in place are not protecting what they are designed to protect.

6.2 Incident InvestigationIn the event of an incident, a proper investigation shall take place to determine the cause of the accident. Once the cause is determined, the manager or supervisor will implement a fix to this problem to prevent this specific accident from happening again.

6.3 AuditA way to determine if the guards implemented are being used and understood, management should conduct quizzes to see if the employees are really understanding on how to use and when to use machine guards.

6.4 Corrective and Preventive ActionsWith any flaws in the program, make the corrective actions necessary to get all guards up to standard. You may have to reteach employees how to correctly use the guards in order to get the point across but this will prevent accidents in the future as well as correct the current problems.

6.5 Feedback and Planning ProcessConduct meetings periodically to hear what employees have to say about the guards implemented and determine from their feedback if what in place is indeed working. If there is negative feedback regarding the guards, determine what fixes could be made to meet their needs in the workplace.

7.0 Management Review7.1 Management Review Process

DIMCO determine their ability to meet the regulations that are required by OSHA. To find out if the guards are up to the correct standards, management can contact an OSHA representative to inspect the facilities machines to evaluate what else should be done to meet the minimum requirements.

7.2 Management Review Outcomes and Follow-UpsReviewing the machine guarding program will be required to maintain standards when need be. When there are major issues concerning complying with OSHA’s standards, management will determine how to implement the corrective measures.