Safety Tidbit #17 - Machine Guarding or LOTO

A colleague recently asked me to put on my “CSP” hat and see what I thought about a rationale given by a client for not putting guards on equipment that had obvious hazards.

“The lathe does not need further guarding.  At the time of our walk through the operator was conducting a machine set up on the first piece to program the lathe for the remaining pipes.  The set up involves constant measuring of the end being cut.  Because of the size of the measuring tools it is not possible to take measurements with the guard in place.  After the lathe is programmed the cutting end guard is in place. 

As to the other machine in question, I discussed the machining process with the operator in regards to the piece he was currently working on.  It took constant tool changing.  Every couple of minutes the machine is disengaged, the tool is disengaged and pushed out from the mill and new tooling is installed.  The machine would be unusable without constant access to tool changing.  It is impossible to change tooling while the machine is in motion.”

From OSHA’s Machine Guarding standard [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.”  The first response seems pretty straight forward when the equipment is in operation; the guard must be in place - period.  (see also OSHA letter of interpretation dated 10/15/1990) 

However, the second response sounds more like they client was thinking of the lockout-tag out (LOTO) standard.  The LOTO standard states: “An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle.” [1910.147(a)(2)(ii)(8)]  However, to complicate matters, an exception “Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production…”  So, many employers are great at explaining how minor the change or the service activity is (even if it involves the worker putting their whole arm into the equipment), and also how the process is not efficient if they have to de-energize the equipment. Ah, there is the rub, to meet the requirements of the exemption the activity must be routine, repetitive, AND integral not just efficient.  Ultimately, the exemption ends with “…provided that the work is performed using alternative measures that provide effective protection. See Subpart O of this Part.”  Which takes us right back to guarding and the ultimate protection of the worker.

Bottom Line: Efficiency at the expense of the worker is NOT very efficient. 
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