Machine Guarding Machine Guarding --LO/TOLO/TO

FPA FPA –– Safety Conference Safety Conference January 2006January 2006

James WashamJames WashamOSHA Region VOSHA Region V

Amputations in Amputations in ManufacturingManufacturing

Over 5,500 amputations Over 5,500 amputations per year and about 21 per year and about 21

fatalitiesfatalitiesOver 40 % related to lo/to issuesOver 40 % related to lo/to issues

In Top 10 Violations For Most In Top 10 Violations For Most IndustriesIndustries

1910.147 1910.147 –– Control of hazardous Control of hazardous energy.energy.

1910.2121910.212 -- General requirements General requirements for all machines. for all machines.

1910.2191910.219 -- Mechanical powerMechanical power--transmission apparatus.transmission apparatus.

Major Causes of AmputationsMajor Causes of Amputations

Inadequate or nonInadequate or non--existing existing safeguards.safeguards.

ByBy--passing safeguards.passing safeguards.

Improperly Applied Safeguards.Improperly Applied Safeguards.

Failure to lockout or isolate energy.Failure to lockout or isolate energy.

OSHA’sOSHA’s General Guarding General Guarding StandardStandard

1910.2121910.212 Types of guarding. One or Types of guarding. One or more methods of machine guarding more methods of machine guarding shall be provided to protect the shall be provided to protect the operator and other employees in the operator and other employees in the machine area from hazards such as machine area from hazards such as those created by point of operation, those created by point of operation, ingoing nip points, rotating parts, ingoing nip points, rotating parts, flying chips and sparks. flying chips and sparks.

SafeguardingSafeguarding

Section 1910.212 is a general machine Section 1910.212 is a general machine guarding standard that applies to all guarding standard that applies to all machinery not otherwise covered by machinery not otherwise covered by Subpart O. The guarding required must be Subpart O. The guarding required must be provided by a "device" that provided by a "device" that does not does not allow reliance upon allow reliance upon the the skillskill or or attentivenessattentiveness of employees. It is of employees. It is "intended to eliminate danger from unsafe "intended to eliminate danger from unsafe operating procedures, poor training or operating procedures, poor training or employee inadvertenceemployee inadvertence

WHERE MECHANICAL WHERE MECHANICAL HAZARDS OCCURHAZARDS OCCUR

Point of operationPoint of operationPower transmission apparatusPower transmission apparatusOther moving partsOther moving parts

Nip pointsNip pointsPinch pointsPinch pointsShear pointsShear pointsRotating partsRotating partsFlying partsFlying parts

METHODS OF GUARDINGMETHODS OF GUARDING

Fixed Barrier (to Fixed Barrier (to prevent access to prevent access to danger)danger)Interlock GatesInterlock GatesAdjustableAdjustableSelfSelf--AdjustingAdjusting

PresencePresence--Sensing Sensing (safety mats, light (safety mats, light curtains)curtains)Safety Pull CordsSafety Pull CordsTwoTwo--Hand ControlsHand Controls

DecisionsDecisions

Different TasksDifferent TasksDifferent Different ExposuresExposuresDifferent HazardsDifferent HazardsDifferent Guarding Different Guarding MethodsMethods

Now What?Now What?

Tasks Based Risk AssessmentTasks Based Risk Assessment

In order to provide adequate In order to provide adequate protection during production protection during production operations including and servicing operations including and servicing and maintenance tasks, all tasks and maintenance tasks, all tasks must be known and evaluated.must be known and evaluated.Many machine hazards are being Many machine hazards are being missed because task identification is missed because task identification is not a part of the processnot a part of the process

ExtruderExtruderTasksTasks

Cleaning Primer Rolls Cleaning Primer Rolls Web Up Web Up Breaker Plate Swap Breaker Plate Swap Rupture Disk Replacement Rupture Disk Replacement Taping and Cleaning of Laminator Nip Taping and Cleaning of Laminator Nip RollsRollsUnloading of Finished Roll Stock at Unloading of Finished Roll Stock at Winder. Winder. Loading / Unloading of Secondary Unwind Loading / Unloading of Secondary Unwind Roll Stock. Roll Stock.

AquaflexAquaflex Pilot Pilot FlexoFlexo PressPressTasksTasks

Loading/unloading a roll of substrate in Loading/unloading a roll of substrate in the unwind sectionthe unwind section..SplicingSplicingWebbingWebbingCorona TreatmentCorona TreatmentChanging Doctor BladeChanging Doctor BladeChanging press components in the Changing press components in the flexoflexodecks and Gravure deck including rolls, decks and Gravure deck including rolls, cylinders, plates, ink metering system, cylinders, plates, ink metering system, etc.etc.

AquaflexAquaflex Pilot Pilot FlexoFlexo PressPressTasksTasks

Making Gravure Doctor Blade Adjustment Making Gravure Doctor Blade Adjustment while printingwhile printingSetting up of the press lamination Setting up of the press lamination operationoperationAssembling and dissembling the die Assembling and dissembling the die stationsstationsCollecting samples from the stacking tableCollecting samples from the stacking tableUnloading a roll of finished substrates Unloading a roll of finished substrates from the from the rewinderrewinderRunning the pressRunning the press

An overview of the steps in TaskAn overview of the steps in Task--Based Based Risk Assessment and ReductionRisk Assessment and Reduction

1. Determine the limits of the 1. Determine the limits of the machine.machine.

2. Determine the tasks to be 2. Determine the tasks to be performed over the lifeperformed over the life--cycle of the cycle of the machine.machine.

3. Identify the hazards associated with 3. Identify the hazards associated with these tasks and rate their severity.these tasks and rate their severity.

An overview of the steps in TaskAn overview of the steps in Task--Based Based Risk Assessment and ReductionRisk Assessment and Reduction

4. For each hazard, establish the 4. For each hazard, establish the probability of a hazardous event.probability of a hazardous event.

5. Determine the level of risk. If it 5. Determine the level of risk. If it is not tolerable is not tolerable -- continue ...continue ...

An overview of the steps in TaskAn overview of the steps in Task--Based Based Risk Assessment and ReductionRisk Assessment and Reduction

6. Eliminate the hazard or reduce its’ 6. Eliminate the hazard or reduce its’ severity. (lessen energy or toxicity)severity. (lessen energy or toxicity)

7. Determine the appropriate 7. Determine the appropriate typetype and and minimum required minimum required level of performancelevel of performance of of protective (safeguarding) measures to protective (safeguarding) measures to provide the desired degree of risk provide the desired degree of risk reduction, using the reduction, using the Safety HierarchySafety Hierarchy as a as a guide.guide.

Hierarchical of Protective MeasuresHierarchical of Protective Measures

Eliminate the hazardEliminate the hazard

Apply safeguardsApply safeguards

Administrative controlsAdministrative controls

GuidanceGuidance

ANSI B11.TR3 ANSI B11.TR3 –– 2000 Risk Assessment 2000 Risk Assessment and Risk Reductionand Risk Reduction

SafeguardingSafeguarding

FlexoFlexo--PressesPresses

ExtrusionExtrusion-- CoatingCoating

Biggest IssueBiggest IssueIn In -- Running Nip PointsRunning Nip Points

NNip Pointsip PointsExtrusion Coating Extrusion Coating –– Laminating StationLaminating Station

Extrusion Rewind NipsExtrusion Rewind Nips

NNip Pointsip PointsExtrusion Laminating StationExtrusion Laminating Station

WinderWinder

NNip Pointsip PointsExtrusion Coating Extrusion Coating –– Laminating StationLaminating Station

Fixed Nip GuardFixed Nip Guard

Shapes of Nip GuardsShapes of Nip Guards

Presence Sensing DevicesPresence Sensing Devices

Safety Safety MatMat

Carton Folder, Gluer and Cutting Carton Folder, Gluer and Cutting OperationOperation

Area ScannersArea Scanners

Movable Guards with Interlocksprevents contact with horizontal movement of hydraulic

screen changer

• Allows electrical system to permit machine operation

• Actuated when guarding is closed or opened

• Prevents movement when the operator is exposed to hazard Electrical Interlock Switch

Interlocked GuardInterlocked Guardinin--running nip of the chill rollsrunning nip of the chill rolls

Electrical Interlock Switch

Emergency stop pull cable

PullPull--Roll NipsRoll Nips

emergency stop pull cord

Sturdy metal mesh in guard

Trim KnivesTrim Knives

trim knife pivoting blade guard

Finishing Blade GuardFinishing Blade Guard

Pressroom SafetyPressroom SafetyIPIP

Aquaflex Producer

6-color Flexo Press with 1 Gravure Station, die cut and sheeter w/high speed stacking table or roll to roll capability.

Pressroom SafetyPressroom SafetySensorsSensorsGuardsGuardsDoor interlocksDoor interlocksSafety stickersSafety stickersCut resistant glovesCut resistant glovesRated hoists and lift devicesRated hoists and lift devicesFire suppressionFire suppressionEE--Stops (emergency stops)Stops (emergency stops)Main cut off switchesMain cut off switchesClear access to equipmentClear access to equipment

Guarded 10 Color Guarded 10 Color FlexoFlexo -- PressPress

Sensors Sensors Unwind and Rewind StandsUnwind and Rewind Stands

Latch open Latch open (top down (top down view), view), NO CONTACT NO CONTACT between sensor and between sensor and latch press will not latch press will not start. Sensor not start. Sensor not satisfied satisfied

Latch closed, Latch closed, CONTACT MADE CONTACT MADE between latch and between latch and sensor sensor -- sensor sensor satisfied satisfied

Guards and InterlocksGuards and Interlocks

Deck guardDeck guard–– When in place protects When in place protects

fingers from NIP points fingers from NIP points during operationduring operation

Deck Guard interlock Deck Guard interlock must be in place to must be in place to operate the pressoperate the press–– When guard is in place the When guard is in place the

interlock pininterlock pin, inserts into , inserts into the the interlock deviceinterlock device

GuardsGuardsFlexo Print StationFlexo Print Station

Stainless steel Stainless steel guard prevents guard prevents fingers from fingers from coming in contact coming in contact with plate cylinder with plate cylinder and anilox roll and anilox roll during press during press operationoperation

GuardsGuardsInIn--feed Nip Rollersfeed Nip Rollers

PlexiglassPlexiglass door door guard to keep guard to keep hands away from hands away from Pinch Points and Pinch Points and still allow still allow visibility during visibility during operation.operation.

Press InterlocksPress InterlocksInterlock device on all Interlock device on all guards guards

Interlock connection Interlock connection pin on guard door. Pin pin on guard door. Pin must plug into press must plug into press interlock to insure interlock to insure guard is in place guard is in place before operationbefore operation

Guards Guards Film TreaterFilm Treater

Doors must be Doors must be closed in order for closed in order for treater to come ontreater to come on

Interlocks must Interlocks must make connection make connection to allow film to allow film treatertreater to operateto operate

Gravure StationGravure Station

PlexiglassPlexiglassDoors with Doors with interlocks. interlocks. (Metal pins are (Metal pins are located on the located on the guard door and the guard door and the safety interlock is safety interlock is mounted on the mounted on the deck frame)deck frame)

Gravure Station (solvent Inks)Gravure Station (solvent Inks)CO2 fire suppression CO2 fire suppression systemsystemInk Kit grounding Ink Kit grounding wireswiresThe gravure deck is The gravure deck is also equipped with also equipped with “explosion proof” “explosion proof” motors and ink motors and ink mixers. mixers. (All motors and (All motors and wires with in an 8’ window wires with in an 8’ window of the gravure deck are of the gravure deck are explosion proof. This explosion proof. This allows solvent ink to be allows solvent ink to be used in the gravure used in the gravure section).section).

Stacker TableStacker Table

When table is When table is pulled into pulled into position, interlock position, interlock must be satisfiedmust be satisfied

Sheeter interlockSheeter interlock

Doctor BladesDoctor Blades

Stainless steel Stainless steel doctor blades are doctor blades are in effect large in effect large razor blades and razor blades and are very sharp, use are very sharp, use cut resistant gloves cut resistant gloves when handling when handling them.them.

1910.1471910.147

Controlling Controlling Hazardous Energy.Hazardous Energy.

Lockout/Lockout/tagouttagout

Purpose: LO/TOPurpose: LO/TO

1.Prevent injury from the 1.Prevent injury from the unexpected startup or unexpected startup or release of stored release of stored energy.energy.

2.Reduce the number of 2.Reduce the number of fatalities and injuries. fatalities and injuries.

3.Establish a program and 3.Establish a program and procedures for procedures for controlling hazardous controlling hazardous energy.energy.

Major provisions of lockout Major provisions of lockout program:program:

1. Machine 1. Machine ProceduresProcedures

2. Training and 2. Training and RetrainingRetraining

3. Audits3. Audits

Types of Energy:Types of Energy:MechanicalMechanicalChemicalChemicalPneumaticPneumaticElectricalElectricalHydraulicHydraulicGravityGravityThermalThermal

Important Definitions:Important Definitions:

Servicing and/or maintenance where Servicing and/or maintenance where employees may employees may be exposed to unexpectedbe exposed to unexpected startstart--up or release of hazardous up or release of hazardous energy:energy:

–– ConstructingConstructing–– Installing and setting upInstalling and setting up–– Adjusting, inspecting, modifyingAdjusting, inspecting, modifying–– Lubricating, cleaning or unLubricating, cleaning or un--jammingjamming–– Tool changes Tool changes

Definitions Definitions (cont’d)(cont’d)

Energy Isolation Devices: Energy Isolation Devices: A mechanical device that physically prevents the A mechanical device that physically prevents the transmission or release of energy, including but transmission or release of energy, including but not limited to the following: A manually not limited to the following: A manually operated electrical circuit breaker; a disconnect operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the switch; a manually operated switch by which the conductors of a circuit can be disconnected from conductors of a circuit can be disconnected from all ungrounded supply conductors.all ungrounded supply conductors.

Definitions Definitions (cont’d)(cont’d)

Energy Isolation Devices:Energy Isolation Devices:

Push buttons, selector switches Push buttons, selector switches and other control circuit type and other control circuit type devices are not energy isolating devices are not energy isolating devicesdevices

3 LO/TO Situations:3 LO/TO Situations:

1.1. Normal/major maintenance, machine Normal/major maintenance, machine shut down.shut down.

2.2. Servicing and maintenance that Servicing and maintenance that takes place during production. LOTO takes place during production. LOTO applies if guards are removed, byapplies if guards are removed, by--passed or operator has to place body passed or operator has to place body in danger zone. in danger zone.

3. Minor servicing and maintenance under 3. Minor servicing and maintenance under the exception:the exception:

Has to take place during normal Has to take place during normal production operations (setproduction operations (set--up?).up?).

Has to be routine, repetitive and integral Has to be routine, repetitive and integral to the production process.to the production process.

Alternative effective protection must Alternative effective protection must be provided.be provided.

Alternative effective protection such as:

• Remote lubricators or other remote devices

• Interlocked gates and barriers• Mechanical blocks, pins, bars, or

locking devices

OSHA’s letters of interpretation 1992 and 2004 OSHA’s letters of interpretation 1992 and 2004 related to minor servicing and alternative related to minor servicing and alternative protection for printing industry protection for printing industry -- summarysummary

In the printing industry, we understand In the printing industry, we understand that the term "minor servicing" that the term "minor servicing" includes,among others, tasks such as includes,among others, tasks such as clearing of clearing of certain typescertain types of paper jams; of paper jams; minor cleaningminor cleaning, lubricating and adjusting , lubricating and adjusting operations; operations; certaincertain plate and blanket plate and blanket changing tasks; and, in changing tasks; and, in some casessome cases, , paper webbing and paper roll changing. paper webbing and paper roll changing.

Letters Letters (cont’d)(cont’d)

One such method of effective alternative One such method of effective alternative protection is the inchprotection is the inch--safesafe--service service technique for the main drive control (see technique for the main drive control (see ANSI B65.1 and B65.2) ANSI B65.1 and B65.2) Employers may use a combination of Employers may use a combination of guarding methods, safe work practices guarding methods, safe work practices and inchand inch--safesafe--service methods.service methods.Under no circumstances can an employee Under no circumstances can an employee reach into danger area while equipment is reach into danger area while equipment is running or energized.running or energized.

Example: Minor ServicingExample: Minor ServicingWhile printing 10 million copies of TV guide, 10 While printing 10 million copies of TV guide, 10 or 15 times a shift, a minor paper jam occurs, or 15 times a shift, a minor paper jam occurs, hickieshickies pop up, the operator raises and pop up, the operator raises and interlocked gate guard, which stops machine interlocked gate guard, which stops machine movement.movement.

The task is taking place during normal production The task is taking place during normal production operations, appears to be routine, repetitive and operations, appears to be routine, repetitive and integral to the production process and alternative integral to the production process and alternative effective protection is provided by the interlocked effective protection is provided by the interlocked guard. guard.

Trim Knives Trim Knives –– Adjusted Adjusted ChangedChanged

PowerPower--Positioned Trim KnivesPositioned Trim Knives

What About Roll Cleaning?What About Roll Cleaning?

Is it minor servicing?Is it minor servicing?Can it be performed Can it be performed with power off and with power off and locked out?locked out?What alternative What alternative protection can be protection can be used?used?

Roll CleaningRoll Cleaning

If power is needed, If power is needed, can the rolls be can the rolls be opened far enough opened far enough to eliminate to eliminate hazard?hazard?Can the rolls be Can the rolls be cleaned from the cleaned from the outout--going nip side?going nip side?Can a nip guard Can a nip guard and a cleaning tool and a cleaning tool be used?be used?

?

Roll CleaningRoll Cleaning

Can a combination Can a combination of guarding and of guarding and inchinch--safesafe--service service method be used?method be used?Can automatic roll Can automatic roll cleaning devices be cleaning devices be used?used?

Power shut off boxes Power shut off boxes

Separate shut off’s.Separate shut off’s.–– The press is divided into The press is divided into

sections for ease of sections for ease of maintenance. Each section maintenance. Each section of press can be of press can be individually shut down for individually shut down for

safety and maintenance.safety and maintenance.

References for Machine Safety:

ANSI Standards B65.1 (2005) ANSI Standards B65.1 (2005)

B11.TR3 B11.TR3 –– 2000 Risk Assessment2000 Risk Assessment

B11.19 B11.19 –– 2003 Performance Criteria for Safeguarding2003 Performance Criteria for Safeguarding

NFPA 79 NFPA 79 –– 2002 Electrical Standard for Industrial 2002 Electrical Standard for Industrial MachineryMachinery

ANSI/SPI B151.7-1996 Plastics Machinery - Plastics Extrusion Machines - Requirements for the Manufacture, Care and Use

WWW.OSHAWWW.OSHA. Gov. Gov

Questions ?Questions ?