Occupational © Safety and Health Administration www .osha.gov Safeguarding Equipment and Protecting Employees from Amputations Sn eee] Pea ey CSE ETO ryOSHA adds value to business, work and life. Employers are responsible for providing a safe and healthful workplace for their employees. OSHA's role is to assure the safety and health of America's employees by setting and enforcing standards; pro- viding training, outreach, and education; establish- ing partnerships; and encouraging continual im- provement in workplace safety and health, This publication is in the public domain and may be reproduced, fully or partially, without permission. Source credit is requested, but not required. This information is available to sensory impaired individuals upon request. Voice phone: (202) 693- 1999; teletypewriter (TTY) number: (877) 889-5627, Edwin G. Foulke, Jr. Assistant Secretary of Labor for ‘Occupational Safety and HealthSafeguarding Equipment and Protecting Employees from Amputations Occupational Safety and Health Administration U.S. Department of Labor OSHA 3170-02R, 2007This OSHA publication is not a standard or regulation, and it creates no new legal obligations. The publication is advisory in nature, informational in content, and is intended to assist employers in providing a safe and healthful workplace. The Occupational Safety and Health Act requires employers to comply with hazard-specific safety and health standards. In addition, pursuant to Section 5(a)(1), the General Duty Clause of the Act, employers must provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm. Employers can be cited for violating the General Duty Clause if there is a recognized hazard and they do not take reasonable steps to prevent or abate the hazard. However, failure to implement these recommendations is not, in itself, a violation of the General Duty Clause. Citations can only be based on standards, regula- tions, and the General Duty Clause.Contents Introduction OSHA Standards National Consensus Standards Recognizing Amputation Hazards Hazardous Mechanical Components Hazardous Mechanical Motions Hazardous Acti Hazard Analysis Controlling Amputation Hazards Safeguarding Machinery Primary Safeguarding Methods Guards Safeguarding Devices Secondary Safeguarding Methods Probe Detection and Safety Edge Devices ‘Awareness Devices Safeguarding Methods Safe Work Procedures Complementary Equipment Ae Inspection and Maintenance Lockout/Tagout Specific Machine Hazards and ‘Safeguarding Methods Hazards of Mechanical Power Presses Safeguarding Mechanical Power Presses Other Controls for Mechanical Power Press Servicing and Maintenance Training Additional Requirements Power Press Brakes Hazards of Power Press Brakes ‘Safeguarding Power Press Brakes Other Controls for Power Press Brakes Hazards of Conveyors ‘Safeguarding Conveyors Other Controls for Conveyors Hazards of Printing Presses ‘Safeguarding Printing Presses Other Controls for Printing Presses Hazards of Roll-Forming and Roll-Bending Machines SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONS ‘Safeguarding Roll-Forming and Roll-Bending Machines Other Controls for Roll-Forming and Roll-Bending Machines Hazards of Shearing Machines ‘Safeguarding Shearing Machi Other Controls for Shearing Machines Hazards of Food Slicers ‘Safeguarding and Other Controls for Food Slicers Hazards of Meat Grinders ‘Safeguarding and Other Controls for ‘Meat Grinders Hazards of Meat-Cutting Band Saws ‘Safeguarding and Other Controls for Meat-Cutting Hazards of Drill Presses ‘Safeguarding and Other Controls for Drill Presses Hazards of Milling Machines ‘Safeguarding and Other Controls for Milling Machines Hazards of Grinding Machines ‘Safeguarding and Other Controls for Grinding Machines Hazards of Slitters ‘Safeguarding and Other Controls for Stitters and Saws OSHA Assistance References Appendix A. Amputation Hazards Not Covered in this Guide Appendix B. Amputation Hazards Associated Appendix C. OSHA Regional Offices 33 34 35 36 36 a7 40 a a2 43 ar 3 3 55List of Tables 1. Commonly Used Machine Guards 12 13 7 7 7 Cutting Action 7 Punching Action 8 Shearing Action 8 Bending Action 8 InRunning Nip Points 8 n Figure 12. Interlocked Guard on a Roll Make-up Machine n Pullback Device on a Power Press 13 Restraint Device on a Power Press 16 Presence-Sensing Device on a Power Press 6 ‘Two-Hand Control 6 Power Press with a Gate 6 Power Press with a Plunger Feed 17 ‘Shuttle Ejection Mechanism 18 Safety Tripod on a Rubber Mill 18 ‘Typical Hand-Feeding Tools 19 Part Revolution Mechanical Power Press with a Two-Hand Control Hand-Feeding Tools Used in Conjunction with Pullbacks on a Power Press Power Press Brake Bending Metal ‘Two-Person Power Press Brake Operation with Pullbacks Belt Conveyor Screw Conveyor Chain Driven Live Rol Stat Conveyor Roll-to-Roll Offset Printing Press Sheet-Fed Offset Printing Press Roll-Forming Machine RollForming 1 Conveyor Band Saw Drill Press with a Transparent Dritt Shietd Bed Mitt Horizontal Surface Grinder Paper Slitter Vth Aaanitaton 26 27 27 28 a a 33 3a 35 35 a7 38 a aa 4s arIntroduction ‘Amputations are among the most severe and dis abling workplace injuries that often result in perma- nent disability. They are widespread and involve various activities and equipment. (The U.S. Bureau of Labor Statistics 2005 annual survey data indicat- ed that there were 8,450 non-fatal amputation cases ~ involving days away from work - for all private industry. Approximately forty-four percent (44%) of all workplace amputations occurred in the manu- facturing sector and the rest occurred across the construction, agriculture, wholesale and retail trade, and service industries.) These injuries result from the use and care of machines such as saws, press es, conveyors, and bending, rolling or shaping machines as well as from powered and non-pow- ered hand tools, forklifts, doors, trash compactors and during materials handling activities. ‘Anyone responsible for the operation, servicing, ‘and maintenance (also known as use and care) of machines (which, for purposes of this publication includes equipment) — employers, employees, safety professionals, and industrial hygienists— should read this publication. Primary safeguarding, as used in this publication, includes control meth- ods that protect (e.g., prevent employee contact with hazardous machine areas) employees from machine hazards through effective machine guard: ing techniques. In addition, a hazardous energy control (lockout/tagout) program needs to comple: ‘ment machine safeguarding methods in order to protect employees during potentially hazardous servicing and maintenance work activities. This guide can help you, the small business employer, identify and manage common amputa- tion hazards associated with the operation and care of machines. The first two sections of the document, Recognizing Amputation Hazards and Controlling Amputation Hazards, look at sources of amputa: tions and how to safeguard machinery and control employee exposure to hazardous energy (lockout! tagout) during machine servicing and maintenance activities. The section on Specific Machinery Hazards and Safeguarding Methods identifies the hazards and various control methods for machinery associated with workplace amputations, such as: mechanical power presses, press brakes, convey: ors, printing presses, roll-forming and roll-bending machines, shears, food slicers, meat grinders, meat: cutting band saws, drill presses, milling machines, grinding machines, and slitting machines. The information in this booklet does not specif: ically address amputation hazards on all types of machinery in general industry, construction, mar: itime and agricultural operations; however, many of the described safeguarding techniques may be used to prevent other amputation injuries. Ad- ditionally, while this manual concentrates attention ‘on concepts and techniques for safeguarding mechanical motion, machines obviously present a variety of other types of energy hazards that cannot be ignored. For example, pressure system failure could cause fires and explosions. Machine electri- cal sources also pose electrical hazards that are addressed by other OSHA standards, such as the electrical standards contained in Subpart S. Full discussion of these matters is beyond the scope of this publication, For compliance assistance purpos- es, references and the appendices are provided on applicable OSHA standards, additional information sources, and ways you may obtain OSHA assistance. OSHA Standards Although this guide recommends ways to safeguard and lockoutitagout energy sources associated with machinery hazards, there are legal requirements in OSHA standards that you need to know about and comply with. The following OSHA standards are a few of the regulations that protect employees from amputation hazards, ‘Machinery and Machine Guarding: 29 CFR Part 1910, Subpart O + 1910.211 ~ Definitions 1910.212~ General requirements for all machines 1910.213 ~ Woodworking machinery require- ments 1910.215 ~ Abrasive whee! machinery 1910.216 - Mills and calenders in the rubber and plasties industries 1910.217 ~ Mechanical power prosses 1910.218 - Forging machines 1910.219 - Mechanical powertransmission apparatus Control of Hazardous Energy (Lockout/Tagout): 29 CFR 1910.147 Hand and Power Toots: 29 CFR Part 1926, Subpart! + 1926.300 - General requirements + 1926.303 - Abrasive wheels and tools + 1926.307 ~ Mechanical powertransmission apparatus Conveyors: 29 CFR 1926.555 SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONSConerete and Masonry Construction 29 CFR Part 1926, Subpart Q + 1926.702 ~ Requirements for equipment and tools Consult these standards directly to ensure full compliance with the provisions as this publication is not a substitute for the standards. States with OSHA-approved plans have at least equivalent standards. For detailed information about machine guarding and lockouttagout, see the following + Machine Guarding Safety and Health Topics Page (httpiwww.osha.goviSLTClmachine guardingjindex.htm) + Machine Guarding eToo! (http:/hwwwosha.gov! SLTCletools/machineguardinglindex.htm!) + OSHA Publication 3067, Concepts and Techniques Cf Machine Safeguarding (http:www.osha.gov! Publications/Mach Safeguardinghtoc.html) + OSHA Directive STD 01-05.019 [STD 1-7.3], Control of Hazardous Energy (Lockout/Tagout) — Inspection Procedures and Interpretive Guidance + Control of Hazardous Energy (Lockout/Tagout) Safety and Health Topies Page (http/iwww.osha. gov/SLTClcontrolhazardousenergylindex.html) + OSHA’ Lockout Tagout Interactive Training Program (http:/hwwwosha.goviatslostal lototraininglindex.htm) OSHA Publication 3120, Control of Hazardous Energy (Lockout/Tagout) OSHA standards, directives, publications, and other resources are available online at ‘www.osha.gov. National Consensus Standards OSHA recognizes the valuable contributions of rational consensus standards and these voluntary standards may be used as guidance and recognition of industry accepted practices. For example, the ‘American National Standards Institute (ANSI) pub- lishes numerous voluntary national consensus stan- dards on the safe care and use of specific machinery. These consensus standards provide you with useful guidance on how to protect your em-ployees from machine amputation hazards and the control methods described may assist you in complying ‘with OSHA performance-based standards. Furthermore, OSHA encourages employers to abide by the more current industry consensus stan. dards since those standards are more likely to be abreast of the state of the art than an applicable OSHA standard may be. However, when a consen- sus standard addresses safety considerations, OSHA may determine that the safety practices described by that consensus standard are less protective than the requirement(s) set forth by the pertinent OSHA regulations. OSHA enforcement policy regarding the use of consensus standards is that a violation of an OSHA standard may be deemed de minimis in nature if the employer complies with a consen- sus standard (that is not incorporated by reference) rather than the OSHA standard in effect and if the ‘employer's action clearly provides equal or greater ‘employee protection. (Such de minimis violations require no corrective action and result in no penalty.) For example, the OSHA point-of-operation ‘guarding provisions, contained in paragraph 1910.212(a)(3), require the guarding device to...be in conformance with any appropriate standards thereof, or in the absence of applicable specitic 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. The terms applicable standards or appropriate stan dards, as used in the context of 29 CFR 1910.212, are references to those private consensus stan- dards that were adopted (source standards) or incorporated by reference in the OSHA standards. In some instances, a specific national consensus standard (that is not incorporated by reference or a source standard), such as an ANSI standard for a particular machine, may be used for guidance pur poses to assist employers in preventing an opera tor from having any body part in the machine dan- {ger zone during the operating cycle. Also, OSHA may, in appropriate cases, use these consensus standards as evidence that machine hazards are rec- ‘ognized and that there are feasible means of cor- recting the hazard. On the other hand, some nation- al consensus standards may sanction practices that provide less employee protection than that provided by compliance with the relevant OSHA provisions. In these cases, compliance with the specific consen- sus standard provision would not constitute compl ‘ance with the relevant OSHA requirement. Under the Fair Labor Standards Act (FLSA), the Secretary of Labor has designated certain non- farm jobs as particularly hazardous for employ: ees younger than 18. Generally, these employ- 08 are prohibited from operating: + Band saws + Circular saws + Guillotine shears * Punching and shearing machines + Meatpacking or meat-processing machines + Certain power-driven machines: Paper products machines, Woodworking machines, Metal forming machines, and Meat slicers. OSHARecognizing Amputation Hazards ‘To prevent employee amputations, you and your ‘employees must first be able to recognize the con- \tibuting factors, such as the hazardous energy associ- ated with your machinery and the specific employee activities performed with the mechanical operation. Understanding the mechanical components of machinery, the hazardous mechanical motion that ‘occurs at or near these components and specific ‘employee activities performed in conjunction with machinery operation will help employees avoid injury. Hazardous Mechanical Components Three types of mechanical components present amputation hazards: Point of Operation is the area of the machine where the machine performs work ~ ie., mechani- cal actions that occur at the point of operation, such as cutting, shaping, boring, and forming, Power-Transmission Apparatus is all components of the mechanical system that transmit energy, ‘such as flywheels, pulleys, belts, chains, couplings, connecting rods, spindles, cams, and gears. Other Moving Parts are the parts of the machine that move while the machine is operating, such as reciprocating, rotating, and transverse mov- ing parts as well as lead mechanisms and auxi lary parts of the machine. Hazardous Mechanical Motions ‘A.wide variety of mechanical motion is potentially hazardous. Here are the basic types of hazardous mechanical motions: Rotating Motion (Figure 1) is circular motion such 2a action generated by rotating collars, couplings, cams, clutches, flywheels, shaft ends, and spin- dles that may grip clothing or otherwise force a body part into a dangerous location. Even smooth surfaced rotating machine parts can be hazardous. Projections such as screws or burrs on the rotat- ing part increase the hazard potential. Figure 1 Rotating Motion Reciprocating Motion (Figure 2) is back-and-forth ‘or up-and-down motion that may strike or entrap ‘an employee between a moving part and a fixed object. Figure 2 Reciprocating Motion Bea (tations) ‘Transversing Motion (Figure 3) is motion in a straight, continuous line that may strike or catch ‘an employee in a pinch or shear point created by the moving part and a fixed object. Figure 3 Tansversing Motion > Aa Cutting Action (Figure 4) isthe action that cuts ‘material and the associated machine motion may be rotating, reciprocating, or transverse. Figure 4 Cutting Action SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONSPunching Action (Figure 5) begins when power ‘causes the machine to hit a slide (ram) to stamp. fr blank metal or other material. The hazard ‘occurs at the point of operation where the ‘employee typically inserts, holds, or withdraws the stock by hand Figure 5 Punching Aetion “» Shearing Action (Figure 6) involves applying power to a slide or knife in order to trim or shear ‘metal or other materials. The hazard occurs at the point of operation where the employee typically inserts, holds, or withdraws the stock by hand. Figure 6 Shearing Aetion Bending Action (Figure 7) is power applied to a slide to draw or stamp metal or other materials in fa bending motion. The hazard occurs at the point of operation where the employee typically inserts, holds, or withdraws the stock by hand, Figure 7 Bending Action u In-Running Nip Points (Figure 8}, also known as pinch points,” develop when two parts move together and at least one moves in rotary or circu lar motion. In-running nip points occur whenever machine parts move toward each other or when ‘one part moves past a stationary object. Typical nip points include gears, rollers, belt drives, and pulleys. Figure 8 In-Running Nip Points plea Nip PintHazardous Activities Employees operating and caring for machinery perform various activities that present potential amputation hazards. Machine set-upithreading/preparation,* Machine inspection,’ Normal production operations, Clearing jams,” Machine adjustments,” Cleaning of machine,* Lubricating of machine parts,” and ‘Scheduled and unscheduled maintenance." * These activities are servicing and/or mainte- nance activities. Hazard Analy: You can help prevent workplace amputations by ooking at your workplace operations and identity- ing the hazards associated with the use and care of the machine. A hazard analysis is a technique that focuses on the relationship between the employee, the task, the tools, and the environment. When evaluating work activities for potential amputation hazards, you need to consider the entire machine operation production process, the machine modes of operation, individual activities associated with the operation, servicing and maintenance of the machine, and the potential for injury to employees. The results from the analysis may then be used as a basis to design machine safeguarding and an overall energy control (lockoutitagout) program, This is likely to result in fewer employee amputa- tions; safer, more effective work methods; reduced workers’ compensation costs; and increased em- ployee productivity and morale. Controlling Amputation Hazards ‘Safeguarding is essential for protecting employees from needless and preventable injury. A good rule to remember is: Any machine part, function, or process that may ‘cause injury must be safeguarded. In this booklet, the term primary safeguarding ‘methods refers to machine guarding techniques that are intended to prevent or greatly reduce the chance that an employee will have an amputation injury. Refer to the OSHA general industry (¢.g., ‘Subpart O) and construction (e.g, Subparts | and N) standards for specific guarding requirements. Many of these standards address preventive meth- ods (such as using barrier guards or two-hand trip- ping devices) as primary control measures; while other OSHA standards allow guarding techniques (such as a self-adjustable table saw guard) that reduce the likelihood of injury. Other less protective safeguarding methods (such as safe work methods) that do not satisfactorily protect employees from the machine hazard areas are considered second- ary control methods. ‘Machine safeguarding must be supplemented by an effective energy control (lockout/tagout) program that ensures that employees are protected from hazardous energy sources during machine servicing and maintenance work activities. Lockout/tagout plays an essential role in the pre- vention and control of workplace amputations. In terms of controlling amputation hazards, employ: es are protected from hazardous machine work activities either by: 1) effective machine safeguard- ing, or 2) lockoutitagout where safeguards are ren- dered ineffective or do not protect employees from hazardous energy during servicing and mainte- nance operations. ‘Additionally, there are some servicing activities, such as lubricating, cleaning, releasing jams and making machine adjustments that are minor in nature and are performed during normal produc- tion operations. It is not necessary to lockout! tagout a machine ifthe activity is routine, repetitive and integral to the production operation provided that you use an alternative control method that affords effective protection from the machine's, hazardous energy sources. Safeguarding Machinery The employer is responsible for safeguarding machines and should consider this need when pur- chasing machinery. Almost all new machinery is, SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONSavailable with safeguards installed by the manufac- turer, but used equipment may not be. If machinery has no safeguards, you may be ‘able to purchase safeguards from the original machine manufacturer or from an after-market manufacturer. You can also build and install the safeguards in-house. Safeguarding equipment should be designed and installed only by technical: ly qualified professionals. If possible, the original ‘equipment manufacturer should review the safe- {guard design to ensure that it will protect employ- ‘ees without interfering with the operation of the machine or creating additional hazards. Regardless of the source of safeguards, the guards and devices used need to be compatible with a machine's operation and designed to ensure safe operator use. The type of operation, size, and shape of stock, method of feeding, physical layout of the work area, and production requirements all affect the selection of safeguards. Also, safeguards should be designed with the machine operator in mind as a guarding method that interferes with the ‘operation of the machine may cause employees to ‘override them. To ensure effective and safe operator Use, guards and devices should suit the operation, The Performance Criteria for Safeguarding [ANSI B11.19-2003] national consensus standard provides valuable guidance as the standard addresses the design, construction, installation, ‘operation and maintenance of the safeguarding Used to protect employees from machine hazards, The following safeguarding method descriptions are, in part, structured like and, in many ways are similar to this national consensus standard. ‘The Performance Criteria for Safeguarding [ANSI B11.19-2003] defines safeguarding as the protec- tion of personnel from hazards by the use of guards, safeguarding devices awareness devices, safeguarding methods, or safe work procedures. The following ANSI B11.19 definitions describe the various types of safeguarding: Guard: A barrier that prevents exposure to an identified hazard. ‘Safeguarding device: A device that detects or prevents inadvertent access to a hazard. NOTE: The 1990 ANSI B11.19 term Safeguarding device was modified to Safeguarding (Protective) Device in the revised 2003 ANSI standard and the ew term includes a detection component. De- vices that detect, but do not prevent employee ‘exposure to machine hazards are not considered by OSHA to be primary safeguarding methods. ‘Awareness device: A barrier, signal or sign that warns individuals of an impending, approaching or present hazard. ‘Safeguarding method: Safeguarding implement- ed to protect individuals from hazards by the physical arrangement of distance, holding, open- ings, or positioning of the machine or machine production system to ensure that the operator cannot reach the hazard, ‘Safe work procedures: Formal written instruc- tions developed by the user which describe how a task is to be performed. Primary Safeguarding Methods Two primary methods are used to safeguard machines: guards and some types of safeguarding devices. Guards provide physical barriers that pre- vent access to danger areas. Safeguarding devices either prevent or detect operator contact with the point of operation or stop potentially hazardous machine motion if any part of an individual's body is within the hazardous portion of the machine. Both types of safeguards need to be properly designed, constructed, installed, used and main: tained in good operating condition to ensure employee protection. Criteria for Machine Safeguarding + Prevents employee contact with the hazard area during machine operation. + Avoids creating additional hazards. + Is secure, tamper-resistant, and durable. + Avoids interfering with normal operation of the machine, + Allows for safe lubrication and maintenance. Guards Guards usually are preferable to other control methods because they are physical barriers that enclose dangerous machine parts and prevent ‘employee contact with them. To be effective, guards must be strong and fastened by any secure method that prevents the guard from being inad- vertently dislodged or removed. Guards typically are designed with screws, bolts and lock fasteners and usually a tool is necessary to unfasten andremove them. Generally, guards are designed not to obstruct the operator's view or to prevent employees from doing a job. In some cases, guarding may be used as an alternative to lockoutitagout because employees, can safely service or maintain machines with a guard in place. For example, polycarbonate and wire-mesh guards provide greater visibility and can be used to allow maintenance employees to safely observe system components. In other instances, employees may safely access machine areas, with- out locking or tagging out, to perform maintenance work (such as machine cleaning or oiling tasks) because the hazardous machine components remain effectively guarded. Guards must not create additional hazards such as pinch points or shear points between guards and other machine parts. Guard openings should be small enough to prevent employees from accessing danger areas. (See Table 7 and Figures 9 through 12 for commonly used machine guards.) Figure 9 Fixed Guard on a Power Press Figure 11. Self-Adjusting Guard on a Radial Saw SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONSTable 1. Commonly Used Machine Guards Types of Machine Guards ‘Type Method of ‘Advantages Limitations ‘Safeguarding Fixed Barrier that allows for Can be constructed to suit | + Sometimes not practical stock feeding but does not many applications. for changing production permit operator to reach Permanently encloses runs involving different the danger area, the point of operation or Size stock or feeding hazard area. methods. Provides protection Machine adjustment and against machine repeat. repair often require guard Allows simple, in-plant removal, construction, with mini- Other means of protecting ‘mal maintenance. maintenance personnel often required (lockouttagout). Adjustable | Barrier that adjusts for Can be constructed to May require frequent a variety of production suit many applications. maintenance or operations. Can be adjusted to admit | adjustment. varying stock sizes. Operator may make guard ineffective, Solt- Barrier that moves Off:the-shelf guards are Does not provide Adjusting | according to the size of the | often commercially avail | maximum protection. stock entering point of able. May require frequent operation. Guard is in place ‘maintenance and when machine is at rest adjustment. and pushes away when stock enters the point of operation Interlocking | Shuts off or disengages Allows access for some May require periodic Barrier power and prevents minor servicing work, in maintenance or adjust- Guards | machine start-up when accordance with the lock- | ment. guard is open. Should ‘outltagout exception, Movable sections cannot allow for inching of without time-consuming bbe used for manual feed- machine. removal of fixed guards. ing Some designs may be easy to defeat. Interlock control circuitry may not be used for all maintenance and servic~ ing work.Safeguarding Devices Safeguarding devices are controls or attachments that, when properly designed, applied and used, usually prevent inadvertent access by employees to hazardous machine areas by: + Preventing hazardous machine component oper- ation if your hand or body part is inadvertently placed in the danger area; + Restraining or withdrawing your hands from the danger area during machine operation; + Requiring the use of both of your hands on, ‘machine controls (or the use of one hand if the control is mounted at a safe distance from the danger area) that are mounted at a predeter- mined safety distance; or + Providing a barrier which is synchronized with the operating cycle in order to prevent entry to the danger area during the hazardous part of the cycle. These types of engineering controls, which either prevent the start of or stop hazardous ‘motion, may be used in place of guards or as supplemental control measures when guards alone do not adequately enclose the hazard, In order for these safeguarding devices to accomplish this requirement, they must be properly designed and installed at a predetermined safe distance from the machine's danger area. Other safeguarding devices (probe detection and safety edge devices) that merely detect, instead of prevent, inadvertent Table 2. Types of Safeguarding Devices access to a hazard are not considered primary safe- guards. (See Table 2 and Figures 13 through 17 for the types of safeguarding devices.) Figure 13 Pullback Device on a Power Pross linked mechanically to ‘the machine automatically ‘withdraw the hands from the point of operation during the machine cycle. feeding and removal. + Provides protection even in the event of mechani: cal repeat. : ‘Types of Machine Guards Type Method of Advantages Limitations ‘Safeguarding Pullback | Cords connected to + Allows the hands to enter | + Close supervision ensures Devices | operator's wrists and the point of operation for | proper use and adjust- ment, Must be inspected prior to each operator ‘change or machine set-up. Limits operator's move- ment and may obstruct their work space, + Operator may easily make device ineffective by not adjusting the device properly. SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONSTable 2. Types of Safeguarding Devices (continued) Types of Machine Guards Type Method of | ‘Advantages Limitations ‘Safeguarding Restraint | Wrists are connected by + Simple, few moving Close supervision re- Devices | cords and secured to a parts; requires little quired to ensure proper fixed anchor point which maintenance. use and adjustment. limit operator's hands from | + Operator cannot reach ‘Must be inspected prior reaching the point of oper- | into the danger area. to each operator change ation at any time, + Little risk of mechanical or machine set-up. failure; provides protec- Operator must use hand tion even in the event of | tools to enter the point of mechanical repeat. operation. Limits the movement of the operator; may obstruct work space around operator. Operator may easily make device ineffective by di connecting the device. Presence- | Interlock into the machine's | + Adjusts to fit different Restricted to machines Sensing | control system to stop stock sizes, that stop operating cycle Devices | operation when the sens- | + Allows access to load before operator can reach ing field (photoelectric, {and unload the machine. into danger area (e.g., radio frequency, or electro | + Allows access to the ‘machines with partial magnetic) is disturbed, ‘guarded area for main- revolution clutches or tenance and set-up hydraulic machines) activities, Must be carefully main- tained and adjusted Does not protect operator in the event of a mechanical failure. Operator may make device ineffective. Presence- | Interlock into machine's + Full visibility and access Restricted to machines Sensing | control system to stop to the work area. that stop operating cycle Mats operation when a predeter- | + Install as a perimeter before operator can reach mined weight is applied to the mat. A manual reset ‘switch must be located out side the protected zone. guard or over an entire Configure for many applications. into danger area (e.g., machines with part- revolution clutches or hydraulic machines) ‘Some chemicals can degrade the mats. Does not protect ‘operator during mechanical failures.Table 2. Types of Safeguarding Devices (continued) Types of Machine Guards Type Method of ‘Advantages Limitations Safeguarding Two- Requires concurrent and Operator's hands are at Requires a partial cycle Hand continued use of both 2 predetermined safety | machine with a brake Controt__ | hands, preventing them distance. and anti-repeat feature. from entering the danger Operator's hands are free | + Operator may make area to pick up new parts after | devices without anti- completion of first part of | tiedown ineffective. cycle. Protects the operator only Two- Requires concurrent use of | * Operator's hands are at, Operator may make Hand Trip | both hands, prevents them | a predetermined safety devices without anti- from being in danger area | distance. tiedown ineffective. when machine cycle starts. | + Can be adapted to Protects the operator multiple operations. only. No obstruction to hand Sometimes impractical feeding because distance require- ments may reduce pro- duction below acceptable level. May require adjustment with tooling changes. Requires anti-repeat feature. Type "A" | Applicable to mechanical Prevents operator from May require frequent Gate power presses. Provides reaching into danger area | _ inspection and regular (move- | barrier between danger during machine cycle. maintenance. able ‘area and operator (or other | + Provides protection from | + May interfere with opera- barrier) | employees) until comple- machine repeat. tor’ ability to see work tion of machine cycle. Type "8" | Applicable to mechanical May increase production | + Can only be used on Gate power presses and press by allowing the operator | machines with a part- (move- | brakes. Provides a barrier | — to remove and feed the revolution clutch or able between danger area and press on the upstroke. hydraulic machines. barrier) | operator (or other employ- May require frequent ees) during the down- stroke. inspection and regular maintenance. May interfere with the operator's ability to see work. SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONSFigure 14 Restraint Device on a Power Press Figure 17 Power Press with a Gato Secondary Safeguarding Methods Other safeguarding methods, such as those described in the Performance Criteria for Safeguarding (ANSI B11.19-2003), may also provide employees with some protection from machine hazards. Detection, safeguarding devices, awareness devices, safo- guarding methods and safe work procedures are described in this section. These methods provide a lesser degree of employee protection than the pri- mary safeguarding methods and they are consid ered secondary control measures as they do not prevent employees from placing or having any part Of their bodies in the hazardous machine areas. Secondary safeguarding methods are accept- able only when guards or safeguarding devices (that prevent you from being exposed to machine hazards) cannot be installed due to reasons of infeasibility. Where itis feasible to use primary safeguarding methods, secondary safeguarding methods may supplement these primary control measures; however, these secondary safeguarding methods must not be used in place of primary safe- guarding methods. Probe Detection and Safety Edge Devices ‘A probe detection device (sometimes referred to as a ring guard) detects the presence or absence of a person's hand or finger by encircling all or part of the machine hazard area. The ring guard makes you aware of your hand's entry into a hazardous ‘rea and usually stops or prevents a hazardous machine cycle or stroke, thereby reducing the likeli- hood of injuring yourself in the point of operation. These types of detection devices are commonly used on spot welders, riveters, staplers and stack-ers because primary safeguarding methods are not, possible. However, probe detection devices do not prevent inadvertent access to the point-of-operation danger area; rather, they serve as a warning mech- anism and may prevent the initiation of or stop the machine cycle if an employee's hand or finger(s) is too close to the hazard area A safety edge device (sometimes called a bump ‘switch) is another type of safeguard that detects the presence of an employee when they are in contact with the device's sensing edge. A safety edge device protects employees by initiating a stop com- mand when the sensing surface detects the pres- ence of a person; however, they do not usually, when used by themselves, prevent inadvertent access to machine danger areas. Therefore, addi- tional guarding or safeguarding devices must be provided to prevent employee exposure to a machine hazard, Awareness Devices ‘Awareness devices warn employees of an impend- ing, approaching or present hazard. The first type is an awareness barrier which allows access to machine danger areas, but itis designed to contact the employee, creating an awareness that he or she is close to the danger point. Awareness signals, through the use of recognizable audible or visual signals, are other devices that alert employees to {an approaching or present hazard. Lastly, aware- ness signs are used to notify employees of the nature of the hazard and to provide instructions and training information. OSHA standard 1910.145 provides design, application, and use specifications for accident prevention (danger, caution, safety instruction) signs and (danger, caution, warning) tags ‘Safeguarding Methods ‘Safeguarding methods protect employees from hazards by the physical arrangement of distance, holding, openings or the positioning of the machine components to ensure that the operator cannot reach the hazard. Some safeguarding work methods include safe distance safeguarding, safe holding safeguarding and safe opening safeguard- ing. Requirements for these secondary control ‘measures may be found in ANSI B11.19-2003. Proper training and supervision are essential to ensure that these secondary safeguarding methods are being used properly. Safeguarding work meth- ods may require the use of awareness devices, including the use of accident prevention signs where there is a need for warning or safety instruction. Safe Distance Safeguarding ‘Safeguarding by safe distance (by location) may involve an operator holding and supporting a work- piece with both hands at a predetermined min ‘mum safe distance or, if both hands cannot be used to hold the work-piece at a distance so that the operator cannot reach the hazard with the free hand. For example, the feeding process itself can create a distance safeguard if the operators main- tain a safe distance between their hands and the point of operation. Additionally, where material position gauges are used, they need to be of suffi cient height and size to prevent slipping of the material past the gauges. ‘Another example of a safe distance safeguard- ing method is the use of gravity feed methods that reduce or eliminate employee exposure to machine hazards as the part slides down a chute into the point of operation. Automatic and semiautomatic feeding and ejection methods can also protect the employee by minimizing or eliminating employee exposure with potentially hazardous machinery components. An employee places the part in a magazine which is then fed into the point of opera- tion. Automatic and semiautomatic ejection methods include pneumatic (jet of ait), magnetic, mechanical (such as an arm), or vacuum. Figures 18 and 19 illustrate different types of automatic feeding and ejecting methods. Figure 18 Power Press with a Plunger Feed SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONSFigure 19 Shuttle Ejection Mechanism te was Pe enti | toa Sy Seah alr ‘Safe Holding Safeguarding (Safe Work-Piece Safeguarding) Operator's hands are maintained away from the hazardous portion of the machine cycle by requir- ing that both hands are used to hold or support the work-piece, or by requiring that one hand holds the work-piece while the other hand operates the machine, For instance, if the stock is Several feet long and only one end of the stock is being worked on, the operator may be able to hold the opposite end while performing the work. The operator's body parts are out of the machine hazard area during the hazardous portion of the machine cycle. However, this work method only protects the operator. ‘Safe Opening Safeguarding This method limits access to the machine haz- ardous areas by the size of the opening or by clos- ing off the danger zone access when the work-piece is in place in the machine. Operators are prevented from reaching the hazard area during the machine ‘operation; however, employee access to the danger area is not adequately guarded when the work- piece is not in place. Safe Work Procedures Safe work procedures are formal, written instruc tions which describe how a task is to be performed. ‘These procedures should incorporate appropriate ‘safe work practices, such as prohibiting employees from wearing loose clothing or jewelry and requir- ing the securing of long hair with nets or caps, Clothing, jewelry, long hair, and even gloves can get ‘entangled in moving machine parts. Complementary Equipment Complementary equipment is used in conjunction with selected safeguarding techniques and it is, by itself, not a safeguarding method. Some common complementary equipment used to augment machine safeguarding include: Emergency Stop Devices Emergency stop devices are designed to be used in reaction to an incident or hazardous situation ‘and, as such, are not considered machine safe- {uarding. These devices, such as buttons, rope- pulls, cable-pulls, or pressure-sensitive body bars, neither detect nor prevent employee exposure to machine hazards; rather they initiate an action to stop hazardous motion when an employee recog- nizes a hazard and activates them. (See Figure 20) Figure 20 Safety Tipod on a Rubber Mill 7 pee S t ‘q Work-Holding Equipment Work-holding equipment is not used to feed or re- move the work-piece, but rather to hold it in place during the hazardous portion of the machine cycle. Clamps, jigs, fixtures and back gauges are exam- ples of work-holding equipment. This equipment may be used to reduce or eliminate the need for an ‘employee to place their hands in the hazard area. Feeding and Ejection Systems ‘A feeding and ejection system (e.g., a gravity fed chute; semi-automatic and automatic feeding and ejection equipment), by itself, does not constitute secondary safeguarding. However, the use of prop- erly designed feed and ejection mechanisms can protect employees by minimizing or eliminating the reed for them to be in a hazard area during the hazardous motion of the machine. Hand-Feeding Tools Operators can use tools to feed and remove materi- al into and from machines so as to keep their hands away from the point of operation. However, this must be done only in conjunction with the guards and safeguarding devices described previ- ously. Hand tools are not point-of-operation guard- 18 OSHA ccupationa ety aning or safeguarding devices and they need to be designed to allow employees’ hands to remain out- side of the machine danger area. Using hand tools requires close supervision to ensure that the opera- tor does not bypass their use to increase produc- tion. It is recommended that these tools be stored near the operation to promote their use. To prevent injury and repetitive trauma disor- ders, hand-feeding tools should be shatterproof and ergonomically designed for the specific task being performed. (Figure 21 shows typical hand- feeding tools.) Figure 21 Typical Hand-Feeding Tools As an employer, you need to consider housekeep- ing practices, employee apparel, and employee training. Implement good housekeeping practices to promote safe working conditions around ma- chinery by doing the following: + Remove slip, trip, and fall hazards from the areas surrounding machines; + Use drip pans when oiling equipment, + Remove waste stock as it is generated + Make the work area large enough for machine operation and maintenance; and + Place machines away from high traffic areas to reduce employee distraction. Employees should not wear loose-fitting cloth: ing, jewelry, or other items that could become entangled in machinery, and long hair should be worn under a cap or otherwise contained to pre- vent entanglement in moving machinery. ‘Adequate instruction in the safe use and care of machines and supervised on-the;job training are essential in preventing amputation injuries. Only trained employees should operate machinery. Foot Controls Foot controls that are not securely fixed at a safe distance do not constitute machine safeguarding because they do not keep the operator's hands out of the danger area. If you use foot-actuated con- trols that are not single-control safeguarding devices, they will need to be used with some type of guard or other safeguarding device. Improperly used foot-actuated controls may increase productivity, but the freedom of hand movement increases the risk of a point-of-operation injury or amputation. Foot controls must be guard- ed to prevent accidental activation by another employee or by falling material. Do not ride the foot pedal. Ensure that the machine control circuit is properly designed to prevent continuous cycling (See Figure 22 for an example of a properly guard- ed foot control.) Train Employees in the Following: + All hazards in the work area, including machine-specific hazards; + Machine operating procedures, lockout/tagout procedures and safe work practices; + The purpose and proper use of machine safe- guards; and + All procedures for responding to safeguarding problems such as immediately reporting un- ‘safe conditions such as missing or damaged {guards and violations of safe operating prac- tices to supervisors. Figure 22 Properly Guarded Foot Control In addition to employee instruction and training, employers need to provide adequate supervision to reinforce safe practices. Take disciplinary ac- tion to enforce safe work practices and working conditions, Inspection and Maintenance Good inspection, maintenance and repair proce- dures contribute significantly to the safety of the maintenance crew as well as to the operators. To ensure the integrity of the machinery and machine safeguards, a proactive, versus a break-down mai SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONS 149tenance program needs to be established based upon the: + Manufacturer's recommendations; + Good engineering practice; and + Any applicable OSHA provisions (such as the mechanical power press inspection and mainte: nance requirements, contained in 1910.217(e). Lockout/Tagout OSHA’ lockoutitagout (LOTO) standard, 29 CFR 1910.147, establishes minimum performance re- quirements for controlling hazardous energy and it is intended to complement and augment machine safeguarding practices. The lockouttagout standard applies only if employees are exposed to hazard- ‘ous energy during servicing/maintenance activities. ‘An employer may avoid the requirements of the LOTO standard if the safeguarding method elimi- nates your employees’ exposure to the machine danger area during the servicing or maintenance work by using Machinery and Machine Guarding methods in accordance with the requirements con: tained in 29 CFR 1910, Subpart O. ‘Additionally, because some minor servicing may have to be performed during normal production ‘operations, an employer may be exempt from LOTO in some instances. Minor tool changes and adjustments and other minor servicing operations, which take place during normal production opera tions, are not covered by lockouttagout if they are routine, repetitive and integral to the use of the machine for production and if work is performed using alternative effective protective measures that provide effective employee protection. In short, a hazardous energy control program is a critical part of an overall strategy to prevent ‘workplace amputations during machine servicing and maintenance activities, such as during the set: ting up of machines for production purposes, by- passing guards to clear jams or lubricate parts, and inspecting, adjusting, replacing, or otherwise serv icing machine parts. Machine amputations occur when an employer does not have or fails to imple- ment practices and procedures to disable and con: trol a machine's energy sources during machine servicing and maintenance work Specific Machine Hazards and Safeguarding Methods ‘As discussed earlier, 8,450 known non-fatal ampu tation cases (involving days away from work) ‘occurred in 2005 for all of private industry. The most prevalent injury source was, by far, machin- ery, which accounted for approximately 60% (5,080 instances) of the amputation cases.’ The machinery listed here cause amputation injuries, and appropri ate safeguarding and hazardous energy control (lockoutltagout) methods are addressed in this sec- tion. Employers need to consult the OSHA standard for specific machinery to ensure compliance with all requirements. For other types of hazardous sources of injury, see Appendix B. Machinery Associated with Amputations Mechanical Power Presses Power Press Brakes Powered and Non-Powered Conveyors Printing Presses Roll-Forming and Roll-Bending Machines Shearing Machines Food Slicers Meat Grinders Meat-Cutting Band Saws 10. Drill Presses 11. Milling Machines 12, Grinding Machines 13. Slitters Hazards of Mechanical Power Presses Although there are three major types of power presses—mechanical, hydraulic, and pneumatic— the machinery that accounts for a large number of workplace amputations are mechanical power presses. In mechanical power presses, tools or dies are mounted on a slide, or ram, which operates in a controlled, reciprocating motion toward and away from the stationary bed or anvil containing the lower die. When the upper and lower dies press together ~ to punch, shear or form - the work- piece, the desired piece is produced. Once the downstroke is completed, the re-formed work-piece * US. Department of Labor, Bureau of Labor Statistics (BLS); Annual Survey data, Table R25. Number of non- fatal Cecupational injuries or illnesses in away from work by source of injury 0 fed natures of injury or illness, 2005,is removed either automatically or manually, a new work piece is fed into the die, and the process is repeated. (See Figure 23) Figure 23. Part Revolution Mechanical Power Press with ‘Two-Hand Control Controls for Machines with Clutches Certain machines can be categorized based on the type of clutch they use—full-revolution or part-revolution. Differing modes of operation for these two clutches determine the type of guard- ing that can be used. Full-revolution clutches, once activated, com- plete a full cycle of the slide (lowering and rais- ing of the slide) before stopping at dead center and cannot be disengaged until the cycle is com- plete. So, presence-sensing devices will not Work and operators must be protected during the entire press operating cycle. For example, properly applied barrier guards or two-hand trip devices that are installed at a safe distance from the hazard area may be used. Machines incorporating full-revolution clutches, such as mechanical power presses, ‘must also incorporate a single-stroke device and anti-repeat feature. The majority of part-revolution presses are air clutch and brake. They are designed to trap air in a chamber or tube. When the compressed air is put into these chambers, the clutch is engaged, the brake disengaged and the press ‘makes a single stroke. To stop the press, the reverse takes place. Thus, the part-revolution clutch can be disengaged at any time during the cycle to stop the cycle before it completes the downstroke, For safeguarding purposes, part-revolution mechanical power presses can be equipped with presence-sensing devices, but full-revolution ‘mechanical power presses cannot. NOTE: Likewise, most hydraulic power presses ‘and their associated control systems are similar to part-revolution mechanical power presses in that the slide can be stopped at any point in the cycle. In order to ensure the integrity of the safety-related functions, safeguarding devices (such as presence- sensing devices) may only be used on hydraulic power presses that are properly designed and con- structed (in accordance with good engineering practice) to accommodate the safeguarding system Refer to OSHA's Machine Guarding eToo! for addi: tional information on hydraulic presses. ‘Amputations occurring from the point of opera- tion hazards are the most common types of injuries associated with mechanical power presses. Improperty applied safeguarding methods (such as Using a guard with more than maximum allowable ‘openings or 2-hand palm buttons that are mounted within the safety distance of the press) may allow operators unsafe access to the press's hazardous area, These unsafe conditions may result in an ‘amputation when an operator, for example, instinc- tively reaches into the point of operation to adjust a misaligned part or release a jam. Also, amputations ‘occur when an operator's normal feeding rhythm is interrupted, resulting in inadvertent placement of the operator's hands in the point of operation. Such injuries usually happen while the operator is riding the foot pedal. Additionally, some amputations are linked to mechanical (such as the failure of a single- stroke linkage), electrical (such as a control relay fai re), or pneumatic (such as the loss of air pressure to the clutch/brake) machine component failure. Examples of inadequate or ineffective safo- guarding and hazardous energy control practices include the following: + Guards and devices disabled to increase produc: tion, to allow the insertion of small-piece work, or to allow better viewing of the operation. + Two-hand tripsicontrols bridged or tied-down to allow initiation of the press cycle using only one hand. + Devices such as pullbacks or restraints improp- erly adjusted. SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONS+ Controls of a single-operator press bypassed by having a coworker activate the controls while the operator positions or aligns parts in the die, or repairs or troubleshoots the press. + Failure to properly disable, isolate press energy ‘sources, and lockoutltagout presses before an ‘employee performs servicing or maintenance work. Case History #1 While using an unguarded, foot-pedal-operated, full-revolution mechanical power press that made trip collars for wood stoves, an employee sed his hands to feed and remove finished parts and scrap metal. He placed the completed part to the left side of the press, and then turned to place the scrap in the bin behind him. As he turned back to face the press, he inadvertently ‘stepped on the foot pedal and activated the press while his hand was in the die area. His left hand ‘was amputated at the wrist. Case History #2 ‘An employee was operating an unguarded 10- ton, full-revolution mechanical power press to ‘stamp mailbox parts, and using a hand tool to load the press, she placed her left hand in the lower die to reposition a misaligned part. At the ‘same time, she inadvertently depressed the foot pedal, activating the press and crushing her left index finger. Case History #3 ‘A power press operator and helper were instruc: ted to temporarily halt production and each ‘employee decided to perform servicing tasks. ‘The operator had a problem with a hydraulic fluid leak and decided to deflect the liquid spray by installing a temporary barrier while, at the ‘same time, the helper decided to clean up the ‘metal chips from the press area. The operator then activated the press and repositioned the press slide in order to install the cardboard barri- fer. This mechanical power press action fatally crushed the helper's head because his head was between the dies while he was in the process of cleaning up the metal chips. Source: OSHA IMIS Accident Investigation Database. the stock size, the length of production runs, and the method of feeding, You can use primary safeguarding methods, such as guards or safeguarding devices, to prevent injuries. For example, 29 CFR 1910.217 requires ‘employers to provide and ensure the use of point of operation guards or properly installed devices on every operation performed on a press when the die ‘opening is greater than "inch. In addition, guards must conform to the maxi- mum permissible openings of Table 0-10 of 29 CFR 1910.217. Guards must prevent entry of hands or fingers into the point of operation through, over, under, or around the guard. ‘Mechanical Power Press Safeguarding Methods by Clutch Type Full-Revolution Clutch __Part-Revolution Clutch Point of Operation Guard Point of Operation Guard Pullback Pulback Restraint Restraint Type A Gate Type A Gate Two Hand Trip Type B Gate* Two-Hand Control* Presence-Sensing Device* *"Hands-in-Die” operations require additional safe- ‘guarding measures: See 1810.217(¢)). Safeguarding Mechanical Power Presses Mechanical power presses are extremely versatile and selecting appropriate safeguarding methods depends on the specific press design and use. You should consider the press, the type of clutch used, ‘Mechanical power press point of operation safe- guards must accomplish the following goals: + Prevent or stop the normal press stroke if the ‘operator's hands are in the point of operation; + Prevent the operator from reaching into the point of operation as the die closes; or + Withdraw the operator's hands if inadvertently placed in the point of operation as the die clos- + Prevent the operator from reaching the point of ‘operation at any time; or + Require the operator to use both hands for the machine controls that are located at such a dis- tance that the slide completes the downward travel or stops before the operator can reach into the point of operation; or + Enclose the point of operation before a press stroke can be started to prevent the operator from reaching into the danger area before die closure or enclose the point of operation prior to stoppage of the slide motion during the downward stroke. Source: 29 CFR 1910.217(¢)(3)(i).“No Hands-in-Die" Policy In general, a “no-hands-in-die” policy needs to be implemented and followed whenever possible ~ that is, in the event the press is not designed for “hands-in-die” production work. Under this policy, operators must never place their hands in the die area (point-of-operation) while perform- ing normal production operations. Adherence to this safety practice will reduce the risk of point of operation amputations. In terms of part-revolution mechanical power presses that Use a two-hand control, presence- sensing device or type B gate, OSHA does allow hands-in-die” operation if the press control reli- ability and brake monitoring system require- ‘ments are met. If these press design safety fea- tures are not complied with, then employers ‘must incorporate a "no-hands-in-die” policy. Source: 29 CFR 1910217(¢)(5). Figure 24 Hand-Feeding Tools Used in Conjunction with Pullbacks on a Power Press. Other Controls for Mechanical Power Press Servicing and Maintenance ‘Secondary safeguarding methods may be used alone or in combination (to achieve near equivalent protection) only when the employer can show that itis impossible to use any of the primary safe- guarding methods. The following are some work practices, complementary equipment and energy control measures that may be used to supplement primary safeguarding: + If employees operate presses under a “no- hands-in-die” policy using complementary feed: ing methods such as hand-tool feeding, employ- ers still must protect operators through the use of primary safeguarding methods, such as a properly applied two-hand control or trip safe- guarding device. Hand-tool feeding alone does ‘Rot ensure that the operator's hands cannot each the danger area. (Figure 24 illustrates the use of hand-feeding tools in conjunction with pulbacks on a power press.) Ram Up-Die Open + Removing scrap or stuck work with tools is required even when hand feeding is allowed according to 29 CFR 1910.217(d)(1)(i). Er- ployers must furnish and enforce the use of hand tools for freeing or removing work or scrap pieces from the die to reduce the amount of time an operator's hand is near the point of operation. + Control point of operation hazards created when guards are removed for setup and repair by operating the machine in the inch mode. This involves using two-hand controls (or a single control mounted at a safe distance from the ‘machine hazards) to gradually inch the press through a stroke when the dies are being tested on part-revolution clutch presses. + Observe energy control procedures and prac- tices for press servicing and maintenance work. For example, the changing of dies on a mechan- ical power press requires the employer to estab- lish a die-setting procedure that employs point- of- operation safeguarding method(s) such as the safe usage of an inch or jog safety device for die set-up purposes together with LOTO. These devices safely position the mechanical power press slide utilizing a point-of-operation safe- guarding technique. Thus, an energy control procedure for these types of presses would SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONS 23need to integrate both point-of-operation safe- guarding method\s) for slide positioning as well as LOTO procedures for the die setting opera: tion. Additional power press energy control precau- tions (e.g., use of safety blocks; LOTO the press dis: connect switch if re-energization presents a hazard) will be necessary if employees need to place their handslarms in a press working area (the space between the bolster plate and the ramislide) to perform the servicing andlor maintenance activity (such as adjusting, cleaning or repairing dies) be- cause the inch or jog safety device will not protect ‘employees from ram movement due to potential mechanical energy (resulting from the ramislide position and associated gravitational force), press ‘component or control system malfunction, or press activation by others. Minor Servicing At times, OSHA recognizes that some minor ‘servicing may have to be performed during nor- ‘mal production operations, so a lockoutltagout ‘exception is allowed. See the 29 CFR 1910.147(a) ii) Note for details. For example, a press oper- ‘ator may need to perform a minor die cleaning task on a regular basis for product quality pur- poses and the use of safety blocks - inserted between the press dies ~ that are interlocked with the press electrical controls would constitute cffective protection. Properly designed and applied safety block interlocks may be used in lieu of locking or tagging out the press's electrical ‘energy source for purposes of the minor servic- ing exception. Source: 29 CFR 1910.147(a)(2)i) Note. 29 CFR 1910.217(e)(1)() requires a program of periodic and regular inspections of mechanical power presses to ensure that all of the press parts, auxiliary equipment and safeguards are in safe operating condition and adjustment. Inspection certification records must be main. tained. 29 CFR 1910.217(e)(1)(i) requires you to inspect {and test the condition of the clutchibrake mech- anism, anti-repeat feature, and single-stroke mechanism on at least a weekly basis for press- ¢ without control reliability and brake system monitoring. Certification records must be main: tained of these inspections and the maintenance performed. 29 CFR 1910.217(g)(1) requires the reporting of all point of operation injuries to operators or other employees within 30 days to either the Director of the Directorate of Standards and Guidance, OSHA, U.S. Department of Labor, Washington, DC 20210, or the state agency administering a plan approved by OSHA. You can also use the Internet to report injuries (aww. osha govipls/powerpress/mechanical htm) ‘Applicable Standards + 29 CFR 1910.147, Control of hazardous energy (lockouthagout). + 29 CFR 1910.217, Mechanical power presses. + 29 CFR 1910219, Mechanical powertransmis- sion apparatus. Training Training is essential for employee protection. As an ‘employer, you shoul + Train operators in safe mechanical press opera- tion and hazardous energy control (lockout! tagout) procedures and techniques before they begin work on the press. + Supervise operators to ensure that correct pro- cedures and techniques are being followed. Additional Requirements In addition, work practices such as regular mechan: ical power press inspection, maintenance, and. reporting are essential ‘Sources of Additional Information + OSHA Instruction CPL 3-00-002 [CPL 2-1.35], National Emphasis Program on Amputations + OSHA Publication 3067, Concepts and Techniques of Machine Safeguarding (httpi/hwww.osha gov/Publications/Mach_ Safeguarditoc.htmi) + OSHA Machine Guarding e Too! (http:/hwww. ‘osha.gov/SLTCletoolsimachineguardinglindex. htm) + OSHA Lockout/Tagout Interactive Training Program (http:/hwww.osha.govidts/ostal lototraininglindex.htm) + NIOSH CIB 49, Injuries and Amputations Resulting From Work with Mechanical Power Presses (May 22, 1987) + OSHA instruction STD 01-12-021 [STD 1- 12.21]-29 CFR 1910.217, Mechanical Power Presses, Clarifications (10/3078) + ANSI B11.1-2001, Safety Requirements for Mechanical Power PressesPower Press Brakes Power press brakes aro similar to mechanical power presses in that they use vertical reciprocat- ing motion and are used for repetitive tasks. Press brake operation is either mechanical or hydraulic. ross brakes are either general-purpose or spe- cial-purpose brakes, according to ANSI B11.3-2002, Safety Requirements for Power Press Brakes. General purpose press brakes have a single opera- tor control station. A servo-system activates the special purpose brake, which may be equipped With multiple operator/helper control stations. (See Figure 25 for a power press brake operation.) Figure 25 Power Press Brake Bending Metal Hazards of Power Press Brakes ‘As with mechanical power presses, point of opera ton injuries are the most common type of injury associated with power press brakes. Here are some frequent causes of amputations from power press brakes: + Foot controls being inadvertently activated while the operator's hand is in the point of operation, The likelihood of this type of injury increases as the size of stock decreases and brings the opera: tor's hands closer to the point of operation, + Parts of the body caught in pinch points created. between the stock and the press brake frame while the bend is being made. + Controls of a single-operator press bypassed by having a coworker activate the controls while the operator positions or aligns stock or repairs or troubleshoot the press. + Failure to properly lockout/tagout presses during the necessary tasks of making adjustments, clearing jams, performing maintenance, installing or aligning dies, or cleaning the machine. Case History #4 ‘An operator was bending small parts using an 80-ton unguarded press brake. This required the employee's fingers to be very close to the point of operation; and, consequently, the operator lost three fingers when his hand entered the point of operation. The operator on the previous shift had reported to the supervisor that the opera- tor placed his fingers close to the point of opera- tion, but was told that nothing could be done and that the operator should be careful. Case History #5 An operator was bending metal parts using a 36- ton part-revolution power press brake that was foot-activated and equipped with a light curtain. About 3-4 inches of the light curtain had been “blanked out” during a previous part run. While adjusting a part at the point of operation, the employee accidentally activated the foot pedal and amputated three fingertips. Safeguarding Power Press Brakes Primary safeguarding methods, such as physical guards and point of operation safeguarding devices (movable barrier devices, presence-sensing de- vices, pull-back devices, restraint devices, single- and two-hand devices) can be used to effectively uard power press brakes. (Figure 26 shows a gen- eral-purpose power press brake used in conjunc- tion with pullbacks.) Some safeguarding methods, such as presence-sensing devices, may require ‘muting or blanking to allow the bending of mater al. Always ensure that these safety devices are properiy installed, maintained, and used in accor- dance with the manufacturer's guidelines for the specific stock and task to be performed. Failure to do so could leave sensing field channels "blanked out” and expose operators to point-of-operation hazards as the safeguarding device's safety di tance increases when blanking is used. SAFEGUARDING EQUIPMENT AND PROTECTING EMPLOYEES FROM AMPUTATIONS 25Figure 26 Two-Person Power Press Brake Operation with Pullbacks In other instances, such as with special-purpose power press brakes, machines are equipped with advanced control systems that are adaptable to all forms of safeguarding concepts and devices, such ‘as two-hand controls and multiple operatorihelper ‘actuating controls. For example, two-hand down, oot through (actuation) methods are used to safe- ‘guard employees while they operate press brakes. With this safeguarding system, an operator uses a ‘two-hand control to lower the press brake ram, for ‘example, to within "inch or less of the lower die (which is considered a safe opening). The operator then has the ability to maneuver and align the work-piece within this It inch safe opening area land he oF she is protected from the amputation hazard. Then the foot control is used by the opera- tor to safely actuate the machine to produce the desired product. Because of constraints imposed by certain man- Lfacturing or fabricating processes, safeguarding by maintaining a safe distance from the point of ‘operation may be acceptable. However, this is per- mitted only when safeguarding by barrier guard or safeguarding devices is not feasible (impossi- bile) ~ that is, where the use of primary safeguard- ing method (such as a restraint device) is not fea- sible, Additional information about a safe distance safeguarding program can be found in OSHA Instruction 02-01-025 [CPL 2-1.25] ~ Guidelines for Point of Operation Guarding of Power Press Brakes. Other Controls for Power Press Brakes The following are some secondary safeguarding methods and complementary equipment that may bbe used to supplement primary safeguarding or alone or in combination when primary safeguard- ing methods are not feasible: + Safe distance safeguarding, + Safe holding safeguarding, + Safe work procedures, + Work-holding equipment (such as back gauges), + Properly designed and protected foot pedals, and + Hand-feeding tools. Ensure that proper safeguarding and lockout! tagout procedures are developed and implemented for power press brakes. Train and supervise em- ployees in these procedures and conduct periodic inspections to ensure compliance. ‘Applicable Standards + 29 CFR 1910.147, Control of hazardous energy (lockouthagout). + 29 CFR 1910.212, General requirements for all ‘machines. + 29 CFR 1910219, Mechanical powertransmis- sion apparatus. ‘Sources of Additional Information + OSHA Publication 3067, Concepts and Techniques of Machine Safeguarding (httpiywww.osha gov/Publications/Mach_ Safeguarditoc.htmi) + OSHA Machine Guarding e Too! (http:/hwww. ‘osha.gov/SLTCletoolsimachineguardinglindex htm) + OSHA Lockout/Tagout Interactive Training Program (http:|iwww.osha.govidtslostal lototraininglindex.htm) + OSHA Directive - CPL 02-01-25 [CPL 2.1.25], Guidelines for Point of Operation Guarding of Power Press Brakes + ANSI B11.3-2002, Safety Requirements for Power Press Brakes Hazards of Conveyors Conveyors are used in many industries to transport materials horizontally, vertically, at an angle, or around curves. Many conveyors have different and unique features and uses, so that hazards vary dueto the material conveyed, the location of the con- vveyor, and the proximity of the conveyer to the employees. Types include unpowered and pow- ered, live roller, slat, chain, screw, and pneumatic. Conveyors eliminate or reduce manual material handling tasks, but they present amputation haz- ards associated with mechanical motion. (See Figures 27 through 30 for examples of common conveyors.) Conveyor-related injuries typically involve a employee's hands or fingers becoming caught in nip points or shear points on conveyors and may ‘occur in these situations: + Cleaning and maintaining a conveyor, especially when itis still operating, + Reaching into an in-going nip point to remove debris or to free jammed material + Allowing a cleaning cloth or an employee's clothing to get caught in the conveyor and pull the employee's fingers or hands into the con- veyor. Other conveyor-related hazards include improp- erly guarded gears, sprocket and chain drives, hori- zontal and vertical shafting, belts and pulleys, and power transmission couplings. Overhead convey- ors warrant special attention because most of the conveyor's drive train is exposed. Employees have also been injured or killed while working in areas underneath conveyors and in areas around lubrica- tion fittings, tension adjusters, and other equipment with hazardous energy sources. Case History #6 While removing a cleaning rag from the ingoing nip point between the conveyor belt and its tail pulley (the unpowered end of the conveyor), an employee's arm became caught in the pulley, which amputated his arm below the elbow. Case History #7 While servicing a chain-and-sprocket drive assembly on a roof tile conveyor system, an employee turned off the conveyor, removed the guard, and began work on the drive assembly without locking out the system. When someone started the conveyor, the employee's fingers became caught in the chain-and-sprocket drive and were amputated, SAFEGUARDING EQUI Figure 27 Belt Conveyor Figure 28 Screw Conveyor Spevttd wlio rs atl soves inven, Figure 29 Chain Driven Live Roller Conveyor