Section 5(a)(1) of the OSH Act, often referred to as the General Duty Clause, requires employers to furnish a place of employment free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.

The following questions should help determine the safeguarding needs of a workplace by drawing attention to hazardous conditions or practices requiring corrections.

Q: Do the safeguards provided meet the minimum OSHA requirements?

Q: Do the safeguards prevent workers’ hands, arms, and other body parts from making contact with dangerous moving parts?

Q: Are the safeguards firmly secured and not easily removable?

Q: Do the safeguards ensure that no objects will fall into the moving parts?

Q: Do the safeguards permit safe, comfortable, and relatively easy operation of the machine?

Q: Can the machine be oiled without removing the safeguard?

Q: Is there a system for shutting down the machinery and locking/tagging out before safeguards are removed?

Q: Can the existing safeguards be improved?

Mechanical hazards Point of Operation:

Q: Is there a point-of-operation safeguard provided for the machine?

Q: Does it keep the operator’s hands, fingers, body out of the danger area?

Q: Is there evidence that the safeguards have been tampered with or removed? Q: Could changes be made on the machine to eliminate the point-of-operation hazard entirely?

Power Transmission Apparatus:

Q: Are there any unguarded gears, sprockets, pulleys, or flywheels on the apparatus?

Q: Are there any exposed belts or chain drives?

Q: Are there any exposed set screws, key ways, collars, etc.?

Q: Are starting and stopping controls within easy reach of the operator?

Q: If there is more than one operator, are separate controls provided?

 Other Moving Parts:

Q: Are safeguards provided for all hazardous moving parts of the machine, including auxiliary parts?

Non-Mechanical Hazards:

Q: Have appropriate measures been taken to safeguard workers against noise hazards? Q: Have special guards, enclosures, or personal protective equipment been provided, where necessary to protect workers from exposure to harmful substances used in machine operation?

Electrical Hazards:

Q: Is the machine installed in accordance with National Fire Protection Association and National Electrical Code requirements?

Q: Are there loose conduit fittings?

Q: Is the machine properly grounded?

Q: Is the power supply correctly fused and protected?

Q: Do workers occasionally receive minor shocks while operating any of the machines?

Safeguards must meet these minimum general requirements:

Prevent contact: The safeguard must prevent hands, arms, and any other part of a worker’s body from making contact with dangerous moving parts. A good safeguarding system eliminates the possibility of the operator or another worker placing parts of their bodies near hazardous moving parts.

Secure: Workers should not be able to easily remove or tamper with the safeguard, because a safeguard that can easily be made ineffective is no safeguard at all. Guards and safety devices should be made of durable material that will withstand the conditions of normal use. They must firmly be secured to the machine.

Protect from falling objects: The safeguard should ensure that no objects can fall into moving parts. A small tool that is dropped into a cycling machine could easily become a projectile that could strike and injure someone.

Create no new hazards: A safeguard defeats its own purpose if it creates a hazard of its own such as a shear point, a jagged edge, or an unfinished surface which can cause a laceration. The edges of guards for instance, should be rolled or bolted in such a way that they eliminate sharp edges.

Create no interference: Any safeguard that impedes a worker from performing the job quickly and comfortably might soon be overridden or disregarded. Proper safeguarding can actually enhance efficiency as it can relieve the worker’s apprehensions about injury.

Allow safe lubrication: If possible, one should be able to lubricate the machine without removing the safeguards. Locating oil reservoirs outside the guard, with a line leading to the lubrication point, will reduce the need for the operator or maintenance worker to enter the hazardous area.

Training

Even the most elaborate safeguarding system cannot offer effective protection unless the worker knows how to use it and why. Specific and detailed training is therefore a crucial part of any effort to provide safeguarding against machine-related hazards. Thorough operator training should involve instruction or hands-on training in the following:

• A description and identification of the hazards associated with particular machines;
• The safeguards themselves, how they provide protection, and the hazards for which they are intended;
• How to use the safeguards and why;
• How and under what circumstances safeguards can be removed, and by whom (in most cases, repair or maintenance personnel only); and
• When a lockout/tagout program is required.
• What to do (e.g., contact the supervisor) if a safeguard is damaged, missing, or unable to provide adequate protection.

This kind of safety training is necessary for new operators and maintenance or setup personnel, when any new or altered safe guards are put in service, or when workers are assigned to a new machine or operation.

Today many builders of single-purpose machines provide point-of-operation and power transmission safeguards as standard equipment. However, not all machines in use have built-in safeguards provided by the manufacturer.

Guards designed and installed by the builder offer two main advantages:

• They usually conform to the design and function of the machine; and

• They can be designed to strengthen the machine in some way or to serve some additional functional purposes. User-built guards are sometimes necessary for a variety of reasons. They have these advantages:

• Often, with older machinery, they are the only practical safeguarding solution. • They may be the only choice for mechanical power transmission apparatus in older plants, where machinery is not powered by individual motor drives;

• They permit options for point-of-operation safeguards when skilled personnel design and make them;

 They can be designed and built to fit unique and even changing situations; and • They can be installed on individual dies and feeding mechanisms. Design and installation of machine safeguards by plant personnel can help to promote safety consciousness in the workplace. User-built guard disadvantages:

• User-built guards may not conform well to the configuration and function of the machine; and

• There is a risk that user-built guards may be poorly designed or built.

Many feeding and ejection methods do not require the operator to place his or her hands in the danger area. In some cases, no operator involvement is necessary after the machine is set up. In other situations, operators can manually feed the stock with the assistance of a feeding mechanism.

Properly designed ejection methods do not require any operator involvement after the machine starts to function. Using these feeding and ejection methods does not eliminate the need for guards and devices. Guards and devices must be used wherever they are necessary and possible in order to provide protection from exposure to hazards. Types of feeding and ejection methods:

Automatic

• Feed Stock is fed from rolls, indexed by machine mechanism, etc.;
• Eliminates the need for operator involvement in the danger area;
• Other guards are required for operator protection, usually fixed barrier guards; • Requires frequent maintenance; and
• May not be adaptable to stock variation.
• Semiautomatic Feed
• Stock is fed by chutes, movable dies, dial feed, plungers, or sliding bolster.

Automatic Ejection
• Work pieces are ejected by air or mechanical means;
• May create a hazard of blowing chips or debris;
• Size of stock limits the use of this method; and
• Air ejection may present a noise hazard.

Semiautomatic Ejection
• Work pieces are ejected by mechanical means which are initiated by the operator;
• Operator does not have to enter danger area to remove finished work;
• Other guards are required for operator protection; and
• May not be adaptable to stock variation.

Machinery Maintenance and Repair
Good maintenance and repair procedures contribute significantly to the safety of the maintenance crew as well as that of machine operators. The variety and complexity of machines to be serviced, the hazards associated with their power sources, the special dangers that may be present during machine breakdown, and the severe time constraints often placed on maintenance personnel all make safe maintenance and repair work difficult.

If possible, machine design should permit routine lubrication and adjustment without removal of safeguards. But when safeguards must be removed, and the machine serviced, the lockout procedure of 29 CFR 1910.147 must be adhered to. The maintenance and repair crew must never fail to replace the guards before the job is considered finished and the machine released from lockout.

In order to prevent hazards while servicing machines, each machine or piece of equipment should be safeguarded during the conduct of servicing or maintenance by:

• Notifying all affected employees (usually machine or equipment operators or users) that the machine or equipment must be shut down to perform some maintenance or servicing;
• Stopping the machine;
• Isolating the machine or piece of equipment from its energy source;
• Locking out or tagging out the energy source;
• Relieving any stored or residual energy; and
• Ensuring that the machine or equipment is isolated from the energy source.

Although this is the general rule, there are exceptions when the servicing or maintenance is not hazardous for an employee, when the servicing which is conducted is minor in nature, done as an integral part of production, and the employer utilizes alternative safeguards which provide effective protection as is required by 29 CFR 1910.212 or other specific standards. When the servicing or maintenance is completed, there are specific steps which must be taken to return the machine or piece of equipment to service. These steps include:
• Inspection of the machine or equipment to ensure that all guards and other safety devices are in place and functional:
• Checking the area to ensure that energization and start up of the machine or equipment will not endanger employees;
• Removal of the lockout devices;
• Re-energization of the machine or equipment; and
• Notification of affected employees that the machine or equipment may be returned to service.

If it is necessary to oil machine parts while the machine is running, special safeguarding equipment may be needed solely to protect the oiler from exposure to hazardous moving parts. Maintenance personnel must know which machines can be serviced while running and which can not. The danger of accident or injury is greatly reduced by shutting off and locking out all sources of energy. FSM