Among the more severe injuries that can occur in the workplace are associated with worker contact with moving metal machine parts. The list of injuries caused by worker contact with moving metal machine parts is numerous and can include amputations of limbs and fingers, crushed fingers and/or hands, lacerations, and abrasions. Also, contact with moving metal machine parts can set off chain reactions that can even prove fatal for workers. Amputations occur to fingers, hands, feet, and other body parts, mostly through compression, crushing, or by getting caught between or struck by objects. Most amputations involve fingertips. Amputation is one of the most severe and crippling types of injuries in the occupational workplace, and often results in permanent disability. Employee exposure to unguarded or inadequately guarded machines is prevalent in many workplaces. As a result, as reported by the Occupational Health and Safety Administration (OSHA), “…workers who operate and maintain machinery suffer approximately 18,000 amputations, lacerations, crushing injuries, abrasions, and over 800 deaths per year” . In fiscal year 2020, of the top ten most frequently cited standards following inspections of work sites by OSHA, the tenth-ranked most cited violation by OSHA was associated with machinery and machine guarding . Whenever operation of a machine or any activity in its vicinity poses the risk of injury to workers, safety mechanisms must be put in place. Safeguards are vital for ensuring maximum protection for workers in an industrial environment. To protect workers from these preventable injuries, it is essential that employers institute safeguards to any machine part, function, or process that may cause injury. The hazards associated with the operation of a machine that may cause accidental contact and injury to an employee or others in the vicinity must be eliminated or controlled through adequate guarding and employee training. All machines consist of the following three fundamental areas:
Despite all machines having the same basic components, their safeguarding needs widely differ due to varying physical characteristics and operator involvement. As indicated by OSHA, a wide variety of mechanical motions and actions may present hazards to the worker. These can include the movement of rotating members, reciprocating arms, moving belts, meshing gears, cutting teeth, and any parts that impact or shear. These different types of hazardous mechanical motions and actions are standard in varying combinations to nearly all machines, and recognizing them is the first step toward protecting workers from the danger they present. The basic types of hazardous mechanical motions and actions are: Motions
Actions
As indicated by OSHA, “Any machine part, function, or process which may cause injury must be safeguarded.” Guarding of machinery is the best way to prevent amputations and other injuries. Guards provide physical barriers to hazardous areas. They should be secure and strong, and workers should not be able to by-pass, remove, or tamper with them. Guards should not obstruct the operator’s view or prevent others from working. OSHA requires employers to ensure the safety of all employees in the work environment, including by providing safeguards to moving parts of machinery to protect against injuries, amputations, and even death. Measures to provide protection to workers on the job site from moving parts of machinery and machines should be included in the preparation of a Health and Safety Plan (HASP), a Job Hazard Analysis (JHA), an Activity Hazard Analysis (AHA), or a Job Safety Analysis (JSA). Image Credit OSHA Standards OSHA standards with which an employer must comply are addressed under the “General Industry” scenario by 29 Code of Federal Regulations (CFR) 1910 Subpart O “Machinery and Machine Guarding” . Other scenarios under which an employer must comply with applicable OSHA standards and regulations or specific portions thereof on guarding include:
As the focus of this article is on the general requirements for all machinery under the General Industry scenario, the reader is referred to the citations previously listed for the other scenarios. There are 28 OSHA-approved State Plans, operating state-wide occupational safety and health programs. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA's and may have different or more stringent requirements. Information on which states have OSHA-approved plans are at this link https://www.osha.gov/stateplans , and should be reviewed for the applicable State that one may be working in. The OSHA general requirements under 29 Code of Federal Regulations (CFR) 1910 Subpart O that apply to the safeguarding of metal-turning equipment that an employer must comply with include: Overall, the primary requirements for all machines under 29 CFR 1910.212 for the “General Industry” scenario are brief and are as follows.
With this regulation, OSHA requires that machine guarding be provided to protect the operators (and other employees) from all hazards. OSHA does not specify which types of safeguards should be used, but includes several examples such as fixed guards, interlocked guards, light curtains, and other similar devices.
Under this regulation, machine guards are required by OSHA to be provided on all machines, and attached to the machine.
Under this regulation, OSHA requires that the guards be designed such that it is not possible to reach the hazard by reaching over, around, under, or through the guard. Furthermore, under 29 CFR 1910.212(a)(3)(iv), OSHA lists some of the machinery that usually requires point of operation guarding: guillotine cutters, shears, alligator shears, power presses, milling machines, power saws, jointers, portable power tools, and forming rolls and calendars.
Under this regulation, OSHA requires that guard enclosures are in place such that revolving drums, barrels, and containers cannot operate if the guard enclosure is not in place.
Requirements for Safeguards Although OSHA does not indicate the specific machine guards that should be used, OSHA has set out a few general requirements that a safeguard must meet to ensure maximum protection. The safeguarding system must have the following features:
An effective guarding system is one that is reliable, durable, and covers all the vulnerable spots during the operation of machinery. During preparation of a Health and Safety Plan (HASP), a Job Hazard Analysis (JHA), an Activity Hazard Analysis (AHA), or a Job Safety Analysis (JSA), OSHA has a web-based tool that can be used to assist in the selection of the appropriate guarding for machinery and machines, and helping one to comply with the OSHA machine guarding standard. This tool is called the “Machine Guarding eTool” . On this web page, OSHA provides information to assist an employer to focus on recognizing and controlling common amputation hazards associated with the operation and use of certain types of machines. Another very useful source of information for employers and workers is the OSHA publication “Safeguarding Equipment and Protecting Employees from Amputations” published in 2007. JSAs are a useful tool that can aid the identification of changed conditions, which can help a work team to develop and agree on revised mitigations at their worksite. Those mitigation revisions can then be immediately documented with a management of change (MOC) annotation right on the JSA. That facilitates helping everybody to complete their tasks safely, in an efficient manner. Performing these MOC steps during reviews help to keep all team members engaged in thinking about their current work tasks and help eliminate potential hazards. A JSA worksheet provides employers so much value so inexpensively, it’s difficult to understand why anyone would not use a Job Safety Analysis for every project task. Go to www.JSAbuilder.com and test the referenced JSA software for free , and help your team work safely and go home at the end of each work day without harm . Follow us on LinkedIn and Twitter @JSABuilder, where we tweet about Health and Safety, post Safety tips, and provide updates on current Health and Safety topics. We also highly recommend that you try one of our other top safety tools at www.LOTOBuilder.com today, where our database-driven Lockout Tagout tool is currently available for a FREE 30-day trial, which will allow you to manage your lock out tag out program from start to finish. Easily enter your workers, equipment and procedures to build an entire LOTO program . Save time and money using LOTOBuilder and help your workers to work safe. Note: images, links, brands discussed or displayed in this article are not endorsements or recommendations. They are for illustration of various products and types of products. JSABuilder does not recommend products, does not endorse, or express any opinion as to the applicability to any given use case or job hazard. Again, consult your safety professional to obtain authoritative opinions on applicability, selection and fitting of all the various types of PPE, then work smart and safe.
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