1363 serious violation, 3 Willful, 12 Repeat. $3.1M 1910.212(a)(1) Types of guarding. 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. 02/11/2004 - Use of laser guarding systems with hydraulic press brakes. CPL 02-01-025 - CPL 2-1.25 - Guidelines for Point of Operation Guarding of Power Press Brakes Discussion . OSHA's machinery and machine guarding regulations (29 CFR 1910 Subpart O) require one or more guarding methods to protect (operating, minor servicing and other nearby) employees from exposure to hazardous machine energy. These methods include guarding by physical barrier(s), by physical device(s), and by maintaining safe distance(s). 1. To protect employees who are not operating or performing minor servicing from exposure to hazardous machine energy, an employer must provide power press brake guarding by physical barrier(s) or by restricting access to power press brakes. 2. A power press brake must not be &quot;energized&quot; (as defined under paragraph 1910.147(b)) when the point of operation is not guarded by one or more physical barriers or physical devices unless: (1) under the operating control of a trained operator (see paragraph F), (2) the operating control of an employee authorized to perform minor servicing which complies with the note following paragraph 1910.147(a)(2)(ii)(B), or as provided under the servicing and maintenance testing and positioning requirements of paragraph 1910.147(f). 3. Employees performing minor servicing on machine(s) or equipment during normal production operations must be protected from exposure to hazardous energy by physical barrier guards and when such guarding is not feasible, by alternative measures which otherwise provide effective protection. When machine(s) or equipment are not in normal production operations, servicing and maintenance must be performed under the control (lockout/tagout) of hazardous energy requirements of paragraph 1910.147 or paragraph 1910.333(b). 4. During normal production operations, the power press brake operator(s) must be protected to the extent feasible by physical barrier(s) or physical device(s) from exposure to hazardous energy sources not at the point of operation and elsewhere on the power press brake. 5. Because of constraints imposed by certain manufacturing or fabricating processes, safeguarding by maintaining a safe distance from the point of operation may be acceptable but only when safeguarding by physical barrier or physical devices is not feasible . &quot;Safe distance&quot; means the clearance between an employee (typically his or her fingers holding and supporting a piece part) and the power press brake point of operation. 6. Safeguarding by maintaining a &quot;safe distance&quot; is acceptable if: a. The employer demonstrates that physical barriers and physical devices are not feasible to guard the power press brake point of operation. Physical devices typically include: two hand controls, holdouts or restraints and presence sensors. b. The employer demonstrates that power press brake point of operation guarding by maintaining a safe distance is limited to one-time only fabrication of made-to-order or custom-made piece parts. Small quantity runs, typically performed in job shop or model shop establishments may be affected by this provision; high volume piece part rates of production will not. A &quot;small quantity run&quot; means fabrication of more than one of the same piece parts over a continuous timeframe of no more than four hours per month. NOTE: Special feasibility guidelines for small quantity runs: When physical guards and physical devices are not feasible for small quantity runs as defined above, safeguarding by maintaining a safe distance as described in this directive is an alternative to power press brake replacement or major renovation which otherwise could provide employee protection. c. The employer has a safety program which includes safe work procedures, training, and supervision to ensure that work is performed using &quot;safe distance&quot; alternative measures. d. The employer has a workplace history of operating power press brakes safely by maintaining a safe distance from the point of operation. Such a history is characterized by absence of injuries related to failure to maintain a safe distance. Workplace history will be evaluated by Compliance Safety and Health Officer review of employer records and interviews or observations of employees. 7. Safeguarding of power press brakes is covered by American National Standards Institute standard ANSI B11.3-1982. OSHA recognizes this ANSI standard as the national consensus standard covering power press brakes guarding. Paragraph 22.214.171.124 or the ANSI B11.3-1982 standard specifically addresses safeguarding by maintaining employee(s) at a safe distance when a power press brake is being operated. By specific notation in paragraph 126.96.36.199, &quot;[a] dimension value has not been assigned to the minimum safe distance.&quot; For the purpose of maintaining a &quot;safe distance&quot; as discussed in this instruction, the operating employee and helping employee(s) must not approach closer than necessary and in no case, closer than 4 inches (10.16 centimeters) to the power press brake point of operation. The minimum safe distance of 4 inches (10.6 cm) shall be measured from the exterior point of contact of the power press brake die closest to an employee. E. &quot;Safe Distance&quot; Safeguarding Program . An employer who adopts &quot;safe distance&quot; protection must have (and be prepared to demonstrate to OSHA) an effective program. An employer can meet this obligation by establishing and having employees follow an effective program which includes exposure prevention procedures and training and enforcement of these procedures as delineated in paragraphs F through J below. F. Exposure Prevention Procedures . A &quot;safe distance&quot; exposure prevention procedure must be developed and documented by the employer and utilized by employee(s). The exposure prevention procedure must include provisions for maintaining a minimum safe distance as discussed in paragraph D.7. above. G. Training . Employees must be trained to follow the aforementioned exposure prevention procedure(s) before operating a power press brake covered under the procedures. 1. Training Content . Employee training must include at least the following: a. The need for a safety oriented working relationship between the power press brake operator and when required, his or her helper. b. The function and purpose of operating controls: operating mode controls; die space height adjustment positions: and other brake controls. c. The hazards of placing any parts of the body within the point of operation. d. The hazards and potential exposure related to each specific piece part bending operation particularly with respect to the piece part itself (for example, whipping) and to tooling (including loading and unloading). e. The function and purpose of hand-feeding tools. f. The dangers of unsafe work practices, inattention, horseplay, and misuse of equipment. g. The necessity and importance of reporting immediately to the supervisor any condition concerning the power press brake and its operation that may affect the safety of an employee. 2. Effectiveness of Training . The employer must ensure that after training, employees perform applicable exposure prevention procedures proficiently. Power press brake operators and helpers must also comply with the safe operating instructions and recommendations of the power press brake manufacturer or industry-recognized safe working practices for power press brakes. [Successful completion of apprenticeship training may be referenced to demonstrate this latter element of employee proficiency.]
1303 Serious violation, 0 willful, 43 repeat. $1.2M 1910.1200(e)(1) Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, material safety data sheets, and employee information and training will be met, and which also includes the following:
746 Serious, 4 willful, 25 repeat. $435K 1910.1200(h)(1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets.
637 serious, 3 willful, 34 repeat. 1.6M 1910.23(c)(1) Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides,
597 Serious, 8 willful, 18 repeat. $1.5M 1910.147(c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist: (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locker-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.
565 Serious. 1 Willful, 13 Repeat. $791k 1910.151(c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
554 Serious, 3 willful, 13 repeat. $1.3M The point of operation of machines whose operation exposes an employee to injury, shall be guarded. The guarding device shall be in conformity with any appropriate standards therefor, or, in the absence of applicable specific standards, shall be so designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle.
Top photo is unguarded.
1910.212(a)(1) Types of guarding. 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.
Top in violation Bottom shows the lower blade guard and anti- kick back device.
1910.212(a)(1) Types of guarding. 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. Also, notice on the slide that there are fixture channels on the shear table that are unguarded. Those channels permit the guards to be bypassed and are often not taken into account when the employer measures the opening between the guard and the table. There was an amputation at Seal Tite a couple of years ago when the operator had his hand go under the guard (we think because of an open fixture channel) and into the blade.
566 serious, 1 willful, 14 repeat. $868K 1910.178(l)(1)(i) The employer shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l).
500 Serious, 0 Willful, 17 Repeat. $312K The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.
597 Serious, 8 Willful, 18 repeat. 1.5M 1910.147(c)(1) Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.
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1. Most Frequently Cited Serious Manufacturing FY2009 OSHA Federal Data January 2010
2. #1 1910.212 (a)(1) <ul><li>Press Brakes </li></ul><ul><li>CPL 02-01-025 - CPL 2-1.25 - Guidelines for Point of Operation Guarding of Power Press Brakes </li></ul>Light Curtains are one method of guarding.
3. #1 1910.212 (a)(1) <ul><li>Lathes </li></ul><ul><li>Need a chip guard for many operations </li></ul><ul><li>When jaws extend past chuck, a guard would be needed. </li></ul>
4. #1 1910.212 (a)(1) <ul><li>Printing presses </li></ul><ul><li>They must be guarded at the in running nip points of the rollers. </li></ul>
5. #1 1910.212 (a)(1) <ul><li>Injection Molding Machine </li></ul><ul><li>Most have interlocked gate as a guarding means. </li></ul>
6. #1 1910.212 (a)(1) <ul><li>Tube Benders </li></ul><ul><li>Pressure mats can be used to avoid the tubes that are being bent. </li></ul>
7. #1 1910.212 (a)(1) <ul><li>Conveyors rotating parts </li></ul><ul><li>The in running nip of the roller fabric and the driver roller can guarded. </li></ul>
8. #2 1910.1200(e)(1) <ul><li>No written hazard communication program </li></ul><ul><li>Must contain a list of hazardous chemicals </li></ul>
9. #3 1910.1200(h) <ul><li>No training employees in the hazards of chemicals </li></ul><ul><li>Signs and symptoms of exposure </li></ul><ul><li>Emergency response </li></ul><ul><li>Health hazards </li></ul>
10. #4 1910.23(c)(1) <ul><li>Open sided floors were not guarded. </li></ul><ul><li>Catwalks, mezzaines, and docks could be cited for this. </li></ul>
11. #5 1910.147(c)(4)(i) <ul><li>This is a common item found in many inspection. </li></ul><ul><li>Boilers, conveyors, cutting machines are common items most commonly left out. </li></ul>
12. #6 1910.151(c) <ul><li>No Eye wash </li></ul>
13. #7 1910.212(a)(3)(ii) <ul><li>Cited for unguarded point of operations </li></ul><ul><li>Point of operation is the area on a machine where work is actually performed upon the material being processed. </li></ul>
14. #7 1910.212(a)(3)(ii) <ul><li>Hydraulic Press </li></ul><ul><li>Cited under this standard vs. the 1910.217 which is for MECHANICAL Presses. </li></ul><ul><li>Similar guarding is required. </li></ul>
15. #7 1910.212(a)(3)(ii) <ul><li>Metal Cutting Saws </li></ul>Unused portion of the blade must be guarded as shown.
16. #7 1910.212(a)(3)(ii) <ul><li>Vertical Bandsaw </li></ul><ul><li>Adjustable guard to height of product </li></ul><ul><li>Many injuries by guiding product into POO </li></ul><ul><li>Handling cold slippery products will increase chances of slipping into POO </li></ul>
17. #7 1910.212(a)(3)(ii) <ul><li>Radial Arm Saws cutting metal </li></ul><ul><li>Lower blade awareness device </li></ul><ul><li>Retracts to original position </li></ul><ul><li>Does not extend past plane of table </li></ul><ul><li>Anti-kick back device </li></ul>
18. #7 1910.212(a)(3)(ii) <ul><li>Shears </li></ul><ul><li>Guards must prevent entry to cutting blade. </li></ul><ul><li>This shear have had its “finger” guards are bent back in violation. </li></ul><ul><li>The slide fails to say that the guard must also prevent access to the hold-downs, </li></ul>
19. #8 1910.178(L)(1) <ul><li>No forklift training </li></ul>
20. #9 1910.134(e)(1) (NEW) <ul><li>No medical evaluation for employees using respirators. </li></ul>
21. #10 1910.147(c)(1) <ul><li>No Written lockout program </li></ul>
22. Resources <ul><li>www.osha.gov </li></ul><ul><li>Compliance Assistance Specialists in OSHA offices </li></ul><ul><li>On-site Consultation </li></ul><ul><li>Quick Takes http://www.osha.gov/as/opa/quicktakes </li></ul><ul><li>OSHA Quick Cards </li></ul><ul><li>Comments or Corrections go to John Newquist </li></ul><ul><li>[email_address] 312-353-5977 </li></ul>