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.

Related Standards

1910.144 & 1910.145

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.

What SIX things must a “SAFEGUARD”

do to protect workers against mechanical hazards?

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

Independent and Redundant Checks

Interlock – Defeated

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.

Trap Key Systems

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.

Safety & Health Topics

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)

OSHA QuickTakes

Free OSHA e-newsletter delivered twice monthly to more than 200,000 subscribers

Latest news about OSHA initiatives and products to help employers and workers find and prevent workplace hazards

Sign up at www.osha.gov

www.osha.gov/quicktakes

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

Eau

Claire

MadisonMilwaukee

Appleton

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

QUESTIONS?

www.osha.gov

800-321-OSHA (6742)

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.