Changing of the Guard

All According to Section 5(a) of the Occupational Safety and Health Act of 1970 (OSH Act), employers are required to furnish a workplace free from recognized safety hazards in order to provide a safe working environment. Although there are several safety requirements that must be taken into consideration for metalworking machines, the most important safety requirement is machine safeguarding.

According to OSHA 29 CFR 1910.212, General Requirements for All Machines, one or more methods of machine safeguarding must be provided to protect the operator and other employees in the machine area from hazards such as those created by the point of operation, ingoing nip points, rotating parts, flying chips, and sparks.

Furthermore, the point of operation of machines whose operation exposes an employee to injury must be safeguarded. The safeguard must comply with any appropriate OSHA standards or, in the absence of applicable specific OSHA standards, must be designed and constructed to prevent the operator from having any part of his or her body in the hazard area during operation of the machine.

Unfortunately, other than the general requirements found in 29 CFR 1910.212, OSHA has only a handful of specific machine-safeguarding standards that apply to metalworking machines. These standards are 29 CFR 1910.215 for abrasive-wheel machinery (grinders), 29 CFR 1910.217 for mechanical power presses, 29 CFR 1910.218 for forging machines, and 29 CFR 1910.219 for mechanical power-transmission apparatuses.

However, these OSHA standards are out of date and do not reflect the most current practices and technology. Therefore, the best standards to reference for machine safeguarding and other safety requirements for metalworking machines are the latest national-consensus standards.

Some of the best national-consensus standards for machine safeguarding are found in the ANSI B11 series for safety on machine tools. This series currently consists of 23 standards and 6 technical reports.

Unlike OSHA standards, the ANSI B11 standards and technical reports are continually revised and updated to reflect the current state of the art. These standards and technical reports include:

? ANSI B11.1-2001 for mechanical power presses (with a 2008 revision that should be approved later this year)
? ANSI B11.2-1995 (reaffirmed in 2005) for hydraulic power presses
? ANSI B11.3-2002 for power press brakes
? ANSI B11.4-2003 for shears
? ANSI B11.5-1998 (reaffirmed in 2002) for ironworkers
? ANSI B11.6-2001 for manual turning machines (lathes) with or without automatic control
? ANSI B11.7-1995 (reaffirmed in 2005) for cold headers and cold formers

? ANSI B11.8-2001 for manual milling, drilling, and boring machines with or without automatic control
? ANSI B11.9-1975 (reaffirmed in 2005) for grinders (with a revision that is underway)
? ANSI B11.10-2003 for metal-sawing machines
? ANSI B11.11-2001 for gear- and spline-cutting machines
?ANSI B11.12-2005 for roll-forming and roll-bending machines
? ANSI B11.13-1992 (reaffirmed in 1998) for single- and multiple-spindle automatic bar and chucking machines (with a revision that is underway)
? ANSI B11.15-2001 for pipe-, tube-, and shape-bending machines

? ANSI B11.16-2003 (MPIF #47) for powder/metal-com-pacting presses
? ANSI B11.17-2004 for horizontal hydraulic extrusion presses
? ANSI B11.18-2006 for machines processing or slitting coiled or noncoiled metal
? ANSI B11.19-2003 for performance criteria for safeguarding (with a revision that is underway)
? ANSI B11.20-2004 for integrated manufacturing systems
? ANSI B11.21-2006 for machine tools using lasers for processing materials
? ANSI B11.22-2002 for turning centers and automatic, numerically controlled turning machines

? ANSI B11.23-2002 for machining centers and automatic, numerically controlled milling, drilling, and boring machines
? ANSI B11.24-2002 for transfer machines
? ANSI B11.TR1-2004 on ergonomic guidelines for machine tools
? ANSI B11.TR2-1997 on mist control of metalworking fluids
? ANSI B11.TR3-2000 on risk assessment and risk reduction (with a revision that is underway)
? ANSI B11.TR4-2004 on the selection of programmable electronic systems (PES/PLC) for machine tools
? ANSI B11.TR5-2006 on sound level measurement guide lines
? ANSI B11.TR7-2007 on designing for safety and lean manufacturing

In addition to these standards and technical reports, a new safety standard and a new technical report are being developed; the standard should be approved this year and the technical report should be approved by next year. They are as follows:

? ANSI B11.GSR-200X for general safety requirements common to ANSI B11 machines
? ANSI B11.TR6-200X on safety control systems for machine tools

For perimeter safeguarding, the best standard to reference is the ANSI/RIA R15.06-1999 safety standard for industrial robots and robot systems. (RIA is the Robotic Industries Association.) Although the particular application may not be a robot or robot system, this standard provides the most detailed guidelines for the proper implementation of perimeter safeguarding.

Another important safeguarding requirement for industrial machinery is that all mechanical power-transmission apparatuses such as belts, pulleys, motor shafts, leadscrews, and chains be safeguarded. OSHA 29 CFR 1910.219 requires everything to be safeguarded up to a 7-ft level above the floor or working platform. ANSI has its own standard, ANSI B15.1-2006, for mechanical power-transmission apparatuses that requires everything to be safeguarded up to a safer level of 8 ft above the floor or working platform.

In addition to safeguarding, metalworking machinery must comply with several electrical requirements. OSHA covers the design of electrical systems in safety standards 29 CFR 1910.302 through 29 CFR 1910.308, which were recently updated and put into effect on August 13, 2007.

However, the updates to these standards were based on the already-outdated 2000 edition of ANSI/NFPA 70E, Electrical Safety Requirements for Employee Workplaces, and the 2002 edition of ANSI/NFPA 70, National Electrical Code (NEC). (NFPA is the National Fire Protection Association.) The latest versions of these standards are the 2004 edition for NFPA 70E and the 2008 edition for the NEC; these versions are the best to reference since they reflect the most current practices and technology.

Another important electrical standard that the ANSI B11 standards reference is ANSI/NFPA 79, Electrical Requirements for Industrial Machinery. The 2007 edition of NFPA 79 is the latest edition; it provides detailed information for the application of electrical/electronic equipment, apparatuses, or systems supplied as part of industrial machinery. This standard addresses such issues as requirements for operator controls, emergency-stop devices, disconnect switches, motor starters, and protective interlocks.

Electrical dangers such as shock, electrocution, and arc flash will always be present on the job, but proper training and safety strategies can minimize the likelihood of injuries and fatalities. OSHA standards 29 CFR 1910.331 through 29 CFR 1910.335 contain safety-related work practices for avoiding the electrical hazards of working on or near exposed, energized parts. Unfortunately, these standards are brief, outdated, and explain only what to do to avoid electrical hazards.

A much better standard that is widely used and accepted is the previously mentioned 2004 edition of NFPA 70E, Standard for Electrical Safety in the Workplace. This standard explains how to avoid electrical hazards. It covers the full range of electrical safety issues, from work practices to maintenance, special equipment requirements, and installation. It even contains requirements for PPE (personal protective equipment) that reflect the latest technology.

Before servicing or maintaining machines, equipment, or processes in which the unexpected release of hazardous energy could cause injury to personnel, certain procedures, techniques, designs, or methods must be followed to protect personnel. The unexpected release of hazardous energy includes any unintended motion, energization, start-up, or release of stored energy, deliberate or otherwise, from the perspective of the person(s) at risk.

The OSHA standard for the control of hazardous energy (lockout/tagout) is 29 CFR 1910.147. However, ANSI Z244.1-2003 is a more comprehensive and up-to-date standard that has been cited in OSHA interpretations and is used by many, if not most, SH&E professionals.

Safety signs are an important part of risk reduction for machinery-they are intended to identify and warn against specific hazards. They may also describe safety precautions, advise evasive actions to take, or provide other directions to eliminate or reduce hazards. Although OSHA has a standard that covers the specifications for accident-prevention signs and tags (29 CFR 1910.145), this standard is outdated and brief.

The best standards to reference when designing or selecting safety signs are the ANSI Z535 standards. These standards specify formats, colors, and symbols for machine safety signs. They also provide information on widely recognized design principles. Use of these standards to develop a uniform visual layout and a consistent system for the recognition of potential hazards will provide the most effective machine safety signs.

One general requirement often overlooked in industrial plants is that proper lighting conditions must exist. According to several of the ANSI B11 standards, lighting must be installed to ensure that personnel can safely perform their tasks. For lighting requirements, the B11 standards reference the ANSI/IESNA RP-7-01 standard, Recommended Practice for Lighting Industrial Facilities. (IESNA is the Illuminating Engineering Society of North America.)

When it comes to machine safety in the metalworking industry, many things must be considered and numerous safety standards must be referenced.

Although OSHA has various standards that can be specifically cited for violations during an OSHA inspection, there are much better national-consensus standards (such as the ANSI B11 series) that cover the same machines or topics, and these standards are more comprehensive and up to date.

Moreover, there are several national-consensus standards for which there are no OSHA equivalents. Therefore, for the safest possible industrial facility, the best practice is to reference and comply with the latest applicable national-consensus standards.

Note: OSHA standards can be accessed online at www.osha.gov or purchased online at http://bookstore.gpo.gov; ANSI standards can be purchased online at http://webstore.ansi.org or www.nssn.org.

Ryan Ebens is the president of Danray Products LLC,
11859 Deacon
Drive, Rockton, IL 61072-9411, 815-
262-6667, Fax:
815-282-5186,
ryan.ebens@danrayproducts.com,
www.danrayproducts.com.