Machine Guarding

[Flying Colors]

We recently had a OSHA visit. They found a few things that we need to get better but all in all it went pretty well.

The main issue we have is with Machine Guarding. Currently, we have the standard emergency bars/cords that everyone else seems to have.

The inspector said we need to have the machine guarded so someone cannot crawl through any opening. I explained that this is the industry standard but the inspector did not seem to be interested in that.

Anyone else have this issue before and is there some sort of exemption we can file?

Mark

[tonypep]

You can try the lock-out tag-out route. Years ago they made us put guards on the back of the dryer over the rollers. He claimed that this was a "nip point"

[TCT]

Dude that SUCKS Mark!!!! So did he have a issue with all your automatics?

That just doesn't seem right(not that I have a clue). It would be hard to believe that the manufacturers of ALL automatics out there would create a machine that would create a immediate OSHA violation.... Hopefully 244 will chime in, I'd wager he would know a thing or two about this.

Please keep us updated Mark, if your inspector is correct we all have something to be worried about! :-

[tonypep]

What is curious to me is that OSHA doesn't go after the mfg (ignorance on my part; could be some territorial issue) Long ago, when some very unfortunate person got his skull crushed on an Oval due to a by-passed safety; OSHA made that company lock the screen side of all of the machines behind fencing. A dead mans switch that cut power to the machines was the only way to get behind the machine. Someone actually died and yet no action taken against the equip mfg. themselves to my knowledge.

[244]

Dude that SUCKS Mark!!!! So did he have a issue with all your automatics?

That just doesn't seem right(not that I have a clue). It would be hard to believe that the manufacturers of ALL automatics out there would create a machine that would create a immediate OSHA violation.... Hopefully 244 will chime in, I'd wager he would know a thing or two about this.

Please keep us updated Mark, if your inspector is correct we all have something to be worried about! :-

Each inspector translates the guidelines differently. We do offer for our machines a full wrap around laser safety system that inspectors way more critical than OSHA has approved. Great for safety but a real pain in production. You can't even card the screens without causing the press to stop.

[TCT]

Thanks for the insight Rich!

Mark are you part of SGIA? Maybe they have some resources to help you. They have a whole new package they are advertising about compliance.

I'd contact Printwear and Impressions/ISS(keep in mind they have the Orlando show this week) also. Not that they would have any answers, but it would be in their best interest to cover(read- add pressure) a situation like this. If this inspector has his way and his "method" of inspecting spreads to other inspectors it could become a big issue for a lot more of us!

[Binkspot]

Rich beat me to it but like he said it's all in the inspectors interpretation of the CFR, not just OSHA but with most regulating agencies. None of them like to proven wrong so it becomes a touchy situation disputing an issue plus I feel a lot of it is job justification. There are provisions under some situations if you can prove the request is unreasonable they will accept a different resolution but if the inspector is hard headed it can become a nightmare.

You may be able to request a review and have another inspector look at the situation, but depending on how much seniority the inspector has it could open a can of worms. If he feels you are trying to side step the situation and has some authority he could make your life difficult.  If you are in good standing with the regulating body, prove to them it's not an issue, provide them with another solution and get a reasonable person hopefully they will work with you. But you have to present them with hard facts not just shop talk.

Like Rich said a laser safety curtain around each press would work but would be costly and hinder production. Same would apply to a cage around the press, I believe that's almost what they do in Canada. Or maybe you could paint a wide yellow stripe around each press with warnings stating do not enter and add a flashing light above each press tied into the indexer. So when the machine is running the light is flashing. 

[TCT]

I've seen the thick yellow painted line many times so HOPEFULLY that may be a good compromise that works.

[Flying Colors]

Thanks everybody for the information and advice, we have not had our closing conference yet so I will find out more then.

We were actually visited by MiOSHA not OSHA, Michigan's version and obviously they have similar rules but from what I can gather a little harsher in certain areas.

Rich- How much is the laser system?

Alex- We are not part of SGIA.

Mark

[Frog]

What is curious to me is that OSHA doesn't go after the mfg (ignorance on my part; could be some territorial issue) Long ago, when some very unfortunate person got his skull crushed on an Oval due to a by-passed safety; OSHA made that company lock the screen side of all of the machines behind fencing. A dead mans switch that cut power to the machines was the only way to get behind the machine. Someone actually died and yet no action taken against the equip mfg. themselves to my knowledge.

My understanding is that OSHA (and I assume the state versions) is only there to protect the safety of employees.
The equipment manufacturers would similarly be held responsible by OSHA guidelines for the equipment that their employees used, not what they are producing.
On a similar note, in a mom and pop with no employees, there is not the same scrutiny.

[244]

Thanks everybody for the information and advice, we have not had our closing conference yet so I will find out more then.

We were actually visited by MiOSHA not OSHA, Michigan's version and obviously they have similar rules but from what I can gather a little harsher in certain areas.

Rich- How much is the laser system?

Alex- We are not part of SGIA.

Mark

The laser system comes two ways. One is a scan laser at the load/unload station and the other is a complete wrap around the press including the scanner. Price for both is around $8,000. We also have to change the program at the same time hence we only do it on M&R machines.

[ZooCity]

SGIA did just offer am OSHA seminar.  State could be different though. 

What about systems that stop the servo motion if a certain amount of resistance is detected? Two mfg have this feature.

Sent from my XT907 using Tapatalk

[244]

SGIA did just offer am OSHA seminar.  State could be different though. 

What about systems that stop the servo motion if a certain amount of resistance is detected? Two mfg have this feature.

Sent from my XT907 using Tapatalk

That can be done if you don't want speed and its a hell of a lot of stopping the press. I have seen this in the field and its a disaster but that's just my opinion.

[TCT]

SGIA did just offer am OSHA seminar.  State could be different though. 

What about systems that stop the servo motion if a certain amount of resistance is detected? Two mfg have this feature.

Sent from my XT907 using Tapatalk

That can be done if you don't want speed and its a hell of a lot of stopping the press. I have seen this in the field and its a disaster but that's just my opinion.

We have that feature on our press and it actually works pretty well.... If the press is running and hits you, you will get a bruise but it wouldn't knock you over or anything. Has no effect on the speed whatsoever.

[244]

SGIA did just offer am OSHA seminar.  State could be different though. 

What about systems that stop the servo motion if a certain amount of resistance is detected? Two mfg have this feature.

Sent from my XT907 using Tapatalk

That can be done if you don't want speed and its a hell of a lot of stopping the press. I have seen this in the field and its a disaster but that's just my opinion.

We have that feature on our press and it actually works pretty well.... If the press is running and hits you, you will get a bruise but it wouldn't knock you over or anything. Has no effect on the speed whatsoever.

What is the maximum index speed on your machine? All machines have mass that must be brought from a stop to a pretty good speed in a short distance. The force to get the inertia moving takes torque which if set too low will trip on start up so I am curious why this is not the case on your machine? I know on the other machine that does this it uses many little motors driving very little mass. on yours there is one drive motor and a lot more mass. Much lower index speed maybe?