In my nearly 21 years of auditing manufacturing plants for compliance with the OSHA machine guarding regulations, I have noticed (in the last couple of years) an ever increasing aggression from OSHA Enforcement in citing companies who allow employees to operate machines with exposed hazard areas. In fact, under the print industry OSHA National Emphasis Program to eliminate amputations, OSHA is now citing companies with older machines that never had guards for some of the hazard areas, even though some of those machines have been in use for decades without any employee injuries resulting from their use.
The time to get serious about your plant’s machine guarding is now, before any employees get hurt, and before OSHA enforcement arrives and cites your company for non-compliance.
OSHA enforcement is actively pursuing machine guarding violations in virtually every state in America. If an employee can place any part of their body or clothing into a nip, crush, cut, entanglement, or electrocution machine hazard area, then that hazard area must be completely guarded. If you have a guard that an employee can reach under, over, or around and still receive an injury from their machine, then you must either extend that guard or replace it with one that cannot be defeated.
When OSHA enforcement visits your plant to see if you have correctly guarded equipment and if you have safety procedures in place to effectively prevent employee amputations, they will likely:
- Examine carefully your last five (5) years of OSHA form 300s and 300As to see if there is any pattern of hand cutting or crushing at your facility.
- Observe machinery operation and question your employees to see if it is possible for any employee to catch their hands, clothing, or hair in moving machinery parts.
- Review your employee Lockout/Tagout formal training and your company’s formal written Lockout/Tagout procedures for each plant machine.
- OSHA is now focusing on whether employers are complying with the requirement to conduct periodic inspections (at least annually) of the energy control procedures (Lockout/Tagout), as required by 20 CFR 1910.147 (c)(6)(i).
How will your company fare under the above scrutiny? Can you produce right now the last five years of correctly completed, signed, and dated OSHA form 300 and 300As? If not, get started now recreating this documentation. Remember, the Form 300A is the injury summary form that must be posted by February 1st in the year that immediately follows the previous year’s reporting period. So for the year 2007, you need a 300A that is signed and dated no later than January 31, 2008 in your file alongside the detailed Form 300.
A sign on your machine that says something like…”Keep Hands out of Hazard Area”, and often has a diagram that shows fingers being crushed, is a clear indication to an OSHA enforcement officer that you have an unguarded hazard area. You must not depend solely on warning signs to protect your employees! Instead, install well designed guards that effectively block your employees’ ability from reaching into (or leaning up against) machine hazard areas. When you look at your company’s machine guarding, please assume your employees will not be thinking clearly, or at all, when operating their machine. And then ask yourself, “is it possible for an employee to place his/her hand or any part of their body into harm’s way, entangle their hair or clothing in their machine, or in any other way get hurt by their access to a machine hazard area?”
Do your employees operate older machines that were never equipped with guards? THERE IS NOT A “GRANDFATHER CLAUSE” THAT ALLOWS FOR THE OPERATION OF OLDER UNGUARDED MACHINERY! Yes, you are expected to retrofit older machines with effective guards that will help keep your employees safe. And, OSHA will inspect your machine guarding, and they will cite you for inadequacies whether you’ve already had injuries in this area or not!
And please examine all hazardous machine areas that are currently guarded, as the guards may not completely cover the hazardous points of operation that they are supposed to guard. For instance, many pulley and chain sprocket guards have an opening in the guards to allow a high speed shaft to spin. But those high speed shafts are supposed to also be guarded with protective metal caps so that no contact can be made with the spinning metal shafts (especially if they are “keyed” or have projections that can harm a person. Additionally, if there are any openings in any guard that a person could slip a little finger past the guard and into “harms way”, then you must close up that gap in the guard!
Even temporarily removing a side panel or guard, to better see a trouble spot in your machine while it is still running, is a violation of the OSHA guarding standard. So, if you are thinking about trouble shooting a machine problem by removing a guard so you can better see the problem, then you’d better first devise a totally effective blockade of access to the troubled machine area so that all employees are as effectively protected as if the guard were still in place.
You may need to “think out of the box” a little bit when devising effective machine guards for older machines. Traditionally, metal or Plexiglas guards are placed directly over the nip point or other machine hazard area. But on some older machines, that would directly impede your production process. Some companies have successfully installed fencing around hazardous machine areas, when the direct application of a guard to the machine hazard area is impractical. Some companies have even inner-locked the fencing to the machine power, so that the machine will not run with the fencing open.
Many of you have older two handed power paper cutters that are relatively safe for your operators, but the back table area of cutters has now been identified as a hand crush hazard area. An employee who is not paying total attention could be standing behind your cutter and place their hand down on the cutter’s back table, and if your cutter operator did not notice the employee in harm’s way at the back table, then he could make an adjustment to your cutter that would crush your other employee’s hand. New cutters either have the back table area totally encased in either a metal or Plexiglas guard, or they have fencing set-up to block access to the back table area.
Please do not allow employees to run their machines without all the guards and side panels always in place. You should write-up an employee and warn them the first time you see them running their machine without all guards in place, and the second time the penalty should escalate maybe to the point of being sent home without pay. Employees have to understand that you will not tolerate this unsafe behavior, and that you will terminate employees who insist on being unsafe by continuing to run machines with guards removed!
President and Certified OSHA Trainer
Assured Compliance Solutions, Inc.