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.
.
.
Thanks for sharing these types of informative article about Machine Guarding. Waiting for your next article.
ReplyDelete