Machine Safeguard, Machining Safety, Machine Hazards

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Abstract-- SAFEGUARDING MACHINE HAZARDS is a common goal for many SH&E professionals.

Operating unguarded equipment introduces risks including the potential for serious injury, equipment damage, increased workers' compensation costs and vulnerability to OSHA citations. Although machine safeguarding has improved since the era prior to the organized safety movement, companies continue to receive OSHA citations and workers continue to be injured, even killed, by machine tools and equipment.

In the early 1900s, transmission machinery (e.g., gears, belts, pulleys, shafting) was often operated while completely unguarded. At that time, the countersunk setscrew used on shafting had not been invented and projecting setscrews were involved in many horrific accidents (Blake 175). Machines were built with little regard for worker safety, meaning that many workers were killed or seriously injured before definitive action was taken to improve safety in the workplace.

The first patent for a machine safeguard was issued in 1868 for a mechanical interlock (Brauer 147). Other patents followed, and as methods for safeguarding machinery and tools were developed, standards were written and programs were established to monitor factories for compliance. Many of those standards continue to govern how workers are protected today. Many machine tools built in the 1940s, 1950s and 1960s are still in use. In terms of safeguarding, these machines may be considered poorly designed, improperly safeguarded or simply unguarded. In addition to the potential threat of OSHA citations, these conditions expose operators to serious hazards.

Enforcement actions, in the form of compliance inspections, are conducted by OSHA (state or federal depending on the location). Federal OHSA requirements for machine guarding are found in 29 CFR 1910, Subpart O: Machinery and Machine Guarding (with specific requirements contained in 1910.211 through 1910.219). Despite improvements in safeguarding, OSHA continues to identify violations at an alarming frequency. Federal data covering October 2001 through September 2002 indicate that machine guarding standards accounted for five of the 13 most frequently cited OSHA standards. Table 1 lists the 20 most frequently cited OSHA standards for the period referenced; those related to machine guarding are highlighted.

One factor in this trend may be the array of hazards that employers must identify. This responsibility is explained in 1910.212(a)(1), which states that one or more methods of machine guarding shall be provided to protect operators and other employees in the machine area from hazards such as those created by the point of operation, ingoing nip points, rotating parts, flying chips and sparks. However, the standard only explains what must be done (provision of one or more methods of machine guarding), not how to do it.

Any of the following potential situations in a work area may be cited as a violation of OSHA standards for machine guarding:

*inadequate ventilation for machines that generate dusts, fumes, vapors, mists or gases;

In many cases, citations are issued because the appropriate safeguard has not been provided or is not in use at the time of inspection. In other cases, interpretations of what the standard requires may vary among OSHA inspectors-in the author's experience, a situation that occurs more frequently for organizations that operate in multiple states. Safeguarding efforts considered adequate in one locale may be considered inadequate in another due to the inspector's interpretation of the standard or application of a staterun OSHA requirement. Therefore, the SH&E professional must be familiar with enforcement practices in various regions in order to help the organization avoid unnecessary citations and associated penalties. The fundamental principle-safeguarding workers-must be the overriding objective at all times and the goal should be to provide a consistent level of protection at each location.

One of the SH&E professional's roles is to monitor operations and advise line management as to what actions are needed with respect to safety. Safety is owned by line management-the responsibility to enforce the program belongs to line management, not the SH&E professional. In many settings, the SH&E professional is tasked with assessing operations and identifying potential hazards and controls associated with machine use. S/he will be expected to write the machine safeguarding program and to help ensure its effective implementation, including employee training.

Once these responsibilities are fulfilled, the SH&E professional should help line management administer the program. First, assess what line management knows about safeguarding machines, then devlop a succinct training course to raise the knowledge base to a satisfactory level. It is helpful to schedule one-on-ones (or small group meetings) with line managers to walk their areas of responsibility and identify operations that present safeguarding hazards. This is also an excellent opportunity to educate managers about hazards and controls in their assigned areas and to help them understand what is expected of them (and workers) so they can appropriately enforce requirements.

As noted, the need for an effective machine safeguarding program is clear based on the number of OSHA citations issued every year. To gain management's support for the program, the SH&E professional should conduct a thorough analysis of the problem. Both passive and active surveillance techniques can be used to obtain the data needed to develop the proposal.

*Review pertinent injury reports to determine the causal factors related to machine-safeguarding-related incidents.

*Tally the number of injuries, lost/restricted workdays and WC costs and assign a realistic monetary value or loss to the organization.

*Review internal/external inspection records to determine the number and type of machine safeguarding deficiencies.

*Document safeguarding hazards using a digital camera and incorporate these photos into the presentation to management as appropriate.

*Verify that deficiencies noted in OSHA citations have been corrected and document whether conditions continue to meet expectations.

The next step is to present the proposal to management. To prepare, practice the presentation, anticipate likely questions and be prepared to explain the anticipated benefits of the program. Also, carefully consider which managers should attend and choose a time when those people can attend.

The written machine safeguarding program should be either a stand- alone document or a section within the overall safety manual. In either case, senior management must endorse it. The written program should clearly define safeguarding requirements and the roles and responsibilities of employees, supervisors and management. The program's objective is straightforward: To ensure adequate safeguarding of machines and tools (and enforcement of their use) in order to maximize productivity and eliminate injuries.

Success is more likely if a group of shop supervisors and workers is involved in the process of developing the program. This is also true when reviewing an existing program. Although the SH&E professional may lead the group due to his/her knowledge of applicable standards, the objective is to achieve buy-in from this group before a new or modified program is implemented.

*roles/responsibilities to clearly articulate what is expected of workers, first-line supervisors, management and the SH&E professional (this element should also be emphasized during training);

*scope of coverage to indiciate that requirements apply to all company-owned machine tools and equipment and all tools and equipment brought on site by contractors;

*requirements broken down by topical area such as general, woodworking tools, metalworking tools, conveyors, belts, pulleys and shafts.

*types of safeguards that describe how and where various types of safeguards are used-and prohibit makeshift safeguards;

*program, assessments which detail who conducts assessments and on what frequency (e.g., initial assignment of safety responsibilities, when new machine tools and/or equipment are purchased);

*Location-specific oper\ator qualification program. A sitewide operator qualification program should be established and the rule enforced that only trained, qualified personnel are allowed to operate machine tools and equipment.

*Workspace layout. Assess the design of the shop floor with these principles in mind:

To develop an effective program, the SH&E professional must understand the principles of safeguarding equipment. As noted, many of these principles have gone largely unchanged since the early 1900s, and many ANSI and OSHA standards have been written with these principles in mind. Although their application and worker compliance may present challenges, the principles themselves are sound and are key to improving operator safety.

1) All power working machines that have gears, sprockets, chains, belts, bands, pulleys, clutches, wheels, shafting, spindles, couplings, counterweights, revolving or reciprocating parts and all other dangerous points, parts or projections are guarded in an approved manner.

2) All roller-fed machines on which operators' hands come within the danger zone are to be guarded at the point of operation in an approved manner.

3) All machines that have a sheering, pressing, squeezing or cutting action on which operators' hands come within the danger zone are to be guarded at the point of operation in an approved manner (Hansen 113).

ANSI is a private, nonprofit entity that coordinates the U.S. voluntary standardization and conformity assessment system. It is recognized as an organization that impacts the adoption, amendment or repeal of OSHA standards. The majority of ANSI standards addressing machinery/equipment safeguarding are found in the B series standards. Examples include:

Many ANSI standards have been adopted by reference in OSHA standards. Others serve as excellent reference and represent the consensus of experts with respect to ensuring worker safety. Therefore, much like being familiar with applicable OSHA standards, the SH&E professional should be aware of applicable ANSI standards.

Machine and/or equipment hazards exist in nearly every type of organization. To identify safeguarding concerns, a detailed assessment of facilities and operations should be conducted. This evaluation should include basements, mechanical rooms, rooftops and other out-of-the-way places. Table 2 illustrates typical machines/ equipment and hazards found in various areas of an industrial facility. This table is not intended as an all-inclusive list of potential hazards, but as an example; those involved should create a site-specific hazard list.

The assessment must be thorough and the evaluator should follow the "operational process path," then walk the extraneous areas. Using a systematic approach helps to ensure that no areas are overlooked. Employee opinions about and concerns regarding safeguarding should be solicited as well. The assessment should focus on the machine/equipment motions and actions (see pg. 22) because these will pose potential hazards to all operators. Housekeeping should also be evaulated, as poor housekeeping practices increase the likelihood of injuries; for example, an employee who trips and falls on debris could become entangled in an operating machine.

Deficient conditions-such as missing or inoperable safeguards- should be promptly communicated to the area manager(s) for correction. Those involved in the assessment must understand company and OSHA requirements for safeguards. Here, the SH&E professional can provide appropriate training to those participating in the assessment.

Identified hazards should be engineered out where feasible, then an appropriate control(s) implemented; these may include engineering controls (guards, barriers, devices), administrative controls and PPE. With respect to safeguarding machines and equipment, deciding whether a guard is necessary may be more difficult than determining which type of safeguard to provide (DeReamer 109). Some questions to be considered in making this determination include:

*Can a person come into direct contact with a moving machine part during normal production/maintenance operations?

*Are rotating or moving screws, keys, bolt heads, burrs or other projections so exposed as to snag a worker's clothing or to inflict injury?

*If tools, jigs or other work fixtures are required, are they stored conveniently but where they will not interfere with the work?

*Is the work area well-illuminated, with additional point-of- operation lighting where necessary?

*Is ventilation adequate, particularly for tasks that create dusts, mists, vapors, fumes or gases?

*Is housekeeping satisfactory, with no debris, tripping hazards or spills on the floor?

Although the fundamental principle of safeguarding machines-to protect operators and coworkers from hazards associated with the operation of those machines-is fairly straightforward, it can be a daunting task. Most hazards emanate from the mechanical motions and actions of the equipment during operation.

The basic types of hazardous mechanical motions are: Rotating (including in-running nip points); reciprocating; and transverse (OSHA 2). Rotation is exemplified by turning shafts, cams, flywheels, etc., and creates the hazard of gripping gloves or clothing and pulling the worker into the machinery or placing him/ her in a dangerous position during the operation of the machine.

Reciprocating motion describes the up-and-down or back-and-forth movement of a machine. The motion creates the hazard of a worker being caught between a moving and stationary part or being struck by the part in motion.

Transverse motion refers to movement in a straight, continuous line. This type of motion exposes the worker to being struck by the moving part or caught in a pinch point or shear point.

The basic types of hazardous mechanical actions are: Cutting, punching, shearing and bending. The actions of machines are somewhat more straightforward and easy to recognize. Hazards associated with machine actions occur at the point of operation where parts of the body (such as fingers, arms or head) can be injured. Flying particles and chips are another potential hazard.

*be made of substantial, durable material and be secured (to the equipment when possible);

The SH&E professional should be involved in the design of safeguards to help ensure that they meet these requirements. Usually, this entails communicating with the safeguard's manufacturer to ensure that the device will provide adequate protection.

To develop an effective program, the SH&E professional must also be familiar with some key terms.

*Device: Mechanism or control designed for safeguarding at the point of operation, such as presence-sensing, pullback, two-hand- trip devices.

*Enclosure: Barrier or cover that protects workers from other danger zones (other than the point of operation) within the operation.

*Nip points or bites: Hazardous area created by two or more mechanical parts that are rotating in opposite directions within the same plane and in close interaction.

*Pinch point: Any place where a body part can be caught between two or more moving parts.

*Point of operation: Area on a machine where material is positioned for processing-where work is actually performed on the material.

*Power transmission: All mechanical parts such as gears, cams, shafts, pulleys, belts, clutches, brakes and rods that transmit energy and motion from the source of power to the equipment or machine.

*Safeguarding: Any means of preventing workers from coming in contact with the moving parts of machinery or equipment, potentially causing physical harm (NSC 382).

OSHA standards (and compliance inspections) are primarily directed at hazards associated with these terms. This makes good sense since noncompliance with requirements related to these hazards places workers at risk of serious injury. Therefore, SH&E professionals should focus on these issues as well.

Effective means of safeguarding machines and equipment include guards (e.g., fixed/enclosure, interlocked, adjustable, self- adjusting); devices (e.g., presence-sensing, pull back, restraint (holdout), safety trip controls, two-hand controls, two-hand trip, gate/cage; and location/distance (e.g, position of operator's control station, distance between machine feeding process a\nd operator's hands). Other means include robotics and automatic feeds.

Guards are usually made of metal, plastic or wood. Metal is often preferred because of its strength and durability. Plastic is typically used in situations that require a higher level of visibility or when it is desirable for the operator to position the guard in relation to the work being performed. Wood guards are flammable and generally lack the durability and strength of guards made of metal or plastic. Use of wood guards is limited by 29 CFR 1910.219(o)(2) as follows:

Wood guards may be used in the woodworking and chemical industries, in industries where the presence of fumes or where manufacturing conditions would cause the rapid deterioration of metal guards; also in construction work and in locations outdoors where extreme cold or extreme heat make metal guards and railings undesirable. In all other industries, wood guards shall not be used.

Fixed guards or enclosures are the preferred type of protection because they prevent operator access to dangerous parts of the machine at all times. This type of safeguard can be applied to many types of equipment including presses, chain and belt drives, rotating shafts, reciprocating parts and gears. The fixed guard can be adjustable to allow for the use of various tools or materials.

Interlocking guards prevent the control that places the machine into operation from working until the guard is in proper position. An interlocking safeguard may be electrical, mechanical, pneumatic or some combination. This guard is "open" when dangerous parts of the machine are exposed and is "closed" when the machine is in operation.

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