Lack of Machine Guarding Again Named to OSHA’S Top 10 Most Cited Violations List

Every year around this time, the awards season kicks off with the Emmys, Golden Globes and the grand daddy of them all, the Oscars, eagerly announcing their lists of nominations. At the same time — and on a far more somber note — another roll call is issued, this one from the Occupational Safety & Health Administration (OSHA). Unlike Hollywood’s awards celebrations, however, no one wants to be nominated for OSHA’s Top Ten Most Cited Violations list, let alone take home the top prize.

OSHA revealed its 2017 Top 10 list at the National Safety Congress & Expo in the Indiana Convention Center. The top ten are:

1. Fall Protection – (1926.501): 6,072 violations
2. Hazard Communication (1910.1200): 4,176 violations
3. Scaffolding (1926.451): 3,288 violations
4. Respiratory Protection (1910.134): 3,097 violations
5. Lockout/Tagout (1910.147): 2,877 violations
6. Ladders (1926.1053): 2,241 violations
7. Powered Industrial Trucks (1910.178): 2,162 violations
8. Machine Guarding (1910.212): 1,933 violations
9. Fall Protection – Training Requirements: 1,523 violations
10. Electrical – Wiring Methods (1910.305): 1,405 violations

While reviewing the list, it is important to remain aware that the Federal Occupational Safety & Health Administration (OSHA) is a small agency. When tallied up to include its state partners, OSHA only has 2,100 inspectors who responsible for the health and safety of 130 million American workers, employed at more than 8 million work sites. This translates to about one compliance officer for every 59,000 workers. As a result, some serious injuries are not reported and thousands of potential violations go without citation or fines. In fact, numerous studies have shown that government counts of occupational injury are underestimated by as much as 50 percent. Employers are required to record all injuries meeting the OSHA’s ‘recordable injury’ criteria (except minor first-aid cases) on the OSHA 300 Log, and those meeting the ‘reportable’ criteria (e.g., hospitalizations or deaths), are to be reported to OSHA immediately, or within 24 hours of occurrence, as per the criteria defined in 29 CFR 1904. But it doesn’t mean all of them do.

MACHINE (UN)SAFEGUARDING IN TOP 10 MOST CITED VIOLATIONS
The absence of required machine safeguarding remains a perennial member of OSHA’s Top 10 Most Cited Violations, and 2017 was no exception. It was named number eight on the list with a total of 1,933 violations. These violations refer to OSHA 1910.212 for failing to have machines and equipment adequately guarded. Any machine part, function, or process that might cause injury should be safeguarded. When the operation of a machine may result in a contact injury to the operator or others in the area, the hazard should be removed or controlled.

A lack of machine safeguarding also held the dubious distinction of making the list of OSHA’s ten largest monetary penalties for the year — not once but four times. In fact, the largest proposed monetary penalty, a staggering $2.6 million (USD), arose from an incident where a worker was crushed to death while clearing a sensor fault in a robotic conveyor belt. OSHA alleges that the company failed to use energy control procedures to prevent robotic machinery from starting during maintenance. The manufacturer also was cited for exposing employees to crushing and amputation hazards as a result of improper machine guarding, plus failing to provide safety locks to isolate hazardous energy.

Despite these headline fines, the repercussions for employers putting workers in harm’s way remain small under the 1970 Occupational Safety and Health Act. The average federal fine for a serious workplace safety violation was $2,402 in fiscal year 2016, according to the most recent report by the AFL-CIO. And the median penalty for killing a worker was $6,500.

According to the most recent Bureau of Labor Statistics data, manufacturing plants reported approximately 2,000 accidents that led to workers suffering crushed fingers or hands, or had a limb amputated in machine-related accidents. The rate of amputations in manufacturing was more than twice as much (1.7 per 10,000 full-time employees) as that of all private industry (0.7). The bulk of these accidents occurred while removing jammed objects from a machine, cleaning or repairing the machine, or performing basic maintenance. These injuries were all largely preventable by following basic machine safeguarding precautions. Rockford Systems is committed to helping organizations reduce injuries and fatalities due to a lack of or non-compliant machine safeguarding. By creating a culture of safety in the workplace, Rockford Systems can help plant managers significantly reduce the number of on-the-job injuries and fatalities that occur annually, plus guard against hefty fines, lost production and increased insurance premiums.

Which leads to the question… “Where do we begin?”

TRAINING AND EDUCATION

Ignorantia juris non excusat (“ignorance of the law excuses not”). Recognizing that education is key to safety, Rockford Systems has offered its Machine Safeguarding Seminars for more than two decades. Thousands of safety professionals have attended the seminars from industries as diverse as aerospace and metal fabrication, to government and insurance.

Held ten times a year at our Rockford, Illinois headquarters, the 2.5 day seminars address key topics in safeguarding with a focus on OSHA 29 CFR and ANSI B-11 standards as they relate to specific machine applications and production requirements. Safeguarding equipment, both old and new, is not only explained in depth in the classroom, but demonstrated under power on the shop floor. Most of these machines are equipped with more than one type of safeguarding product so that attendees can see how different guards and devices can be applied.

Roger Harrison, Director of Training for Rockford Systems and an industrial safeguarding expert with over 25,000 hours of training experience, conducts the Machine Safeguarding Seminar.

>Another valuable educational resource is OSHA-10 General Industry and OSHA-30 General Industry training courses, both of which cover machine guarding. All of our training can be provided at your site, if preferred. To learn more about the Rockford Systems training curriculum, please visit https://www.rockfordsystems.com/seminars/

Rockford Systems also provides a variety of FREE machine safeguarding resources for your organization. Please visit our RESOURCES page to find videos, blogs, quick reference sheets, and more or visit our YouTube channel to download past webinar recordings.

ASSESSMENTS
If your organization is interested in safeguarding solutions, consider a Machine Risk Assessment or Machine Safeguarding Assessment as the critical first step in any machine guarding process as outlined in ANSI B11. Most assessments, but not all, follow the basic steps outlined below.

Step 1 – Provide Machine List
To get started, please provide Rockford Systems a list of all machines (manufacturer, model number, and machine description of each machine) to be assessed. This machine list is needed to determine the estimated resource requirement for the onsite audit. Upon receipt of your machine list, an Assessment Proposal will be provided, generally within 24 hours of receipt. Please email your machine list and any machine photos (optional) to sheryl.broers@rockfordsystems.com.

Step 2 – Schedule Onsite Visit
During the assessment, a machine safeguarding specialist will visit your site and conduct a complete audit of all machines identified on the list and evaluate their compliance in five guarding areas (Safeguards, Controls, Disconnects, Starters, and Covers). The assessment is based on OSHA 1910.212 General Requirements (a)(1), ANSI B11 Safety Standards for Metalworking, ANSI/RIA R15.06-2012 Safety Standards for Industrial Robots, and NFPA 79. If Rockford Systems, LLC has additional specific safeguarding requirements above and beyond OSHA 1910.212 and ANSI B11, please provide them before the site visit and we will incorporate them into the assessment.

Also, during the assessment, we may request copies of electrical, pneumatic and/or hydraulic schematics and operator manuals for specific machines. This information is needed for our Engineering Department to review the control circuit for electrical compatibility of equipment being offered, to verify control reliability of the control circuit, to determine interfacing requirements of suggested equipment. If requested, this information would be needed before advancing to Step 3 below.

Step 3 – Receive Compliance Report and Safeguarding Project Proposal
Upon completion of the assessment, a Compliance Report and Safeguarding Project Proposal will be provided to that identifies where each machine is in, or not in, compliance with the above stated regulations and standards. Where not in compliance, we will suggest guarding solutions to bring the machines into compliance, along with associated costs and timeframes.

We look forward to assisting your organization with its safeguarding needs. A team member will call you within 24 hours to further discuss your needs and applications. We are here to help businesses large and small address machine safety challenges and to remove the burden of managing the growing legal complexity of OSHA, ANSI and NFPA requirements from simple turnkey solutions to build-to-spec customized solutions.

Please contact sheryl.broers@rockfordsystems.com or call 1-815-874-3648 (direct) to get started on an assessment today.

PRODUCTS
If you are looking for Machine Safeguarding Products, please visit our PRODUCTS page that offers over 10,000 safeguarding solutions for drill presses, grinders, lathes, milling machines, press brakes, power presses, radial arm drills, riveters and welders, robots, sanders, saws and more.

RETURN ON INVESTMENT
Not sure if the investment in machine safeguarding provides a return on the investment (ROI), it absolutely does and we can help you calculate it. Please read our detailed blog post on this topic.

For more information on how avoid machine injuries and fatalities, please visit www.rockfordsystems.com.

Safeguarding Lathes

Lathes are often overlooked when Risk Assessments are conducted to determine appropriate “Machine Safeguarding.” OSHA regulations consider lathes to be a 1910.212 machine, saying to the employer, “One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips, and sparks” … but 1910.212 requirements are vague because they cover such a wide variety of machinery. Therefore, a reference to something more detailed, like ANSI B11.6 on metalworking lathes, is required for specific safeguarding alternatives.

From a practical standpoint, the rotating chuck (work-holder) cannot be fully enclosed, unlike gears, sprockets, or chains which can and usually are completely covered, often by the machine’s manufacturer. However, that same lathe manufacturer may provide no safeguarding at or near the point of operation.

Hinged chuck-shields are one of the most common methods to protect lathe operators from the rotating work-holder. Their purpose is to prevent an operator from inadvertently coming in contact with the chuck, which often results in entanglement with it, resulting in serious injury or even death. Chuck shields are commercially available from numerous providers. They may be constructed of metal, polycarbonate, or some combination of materials. When not in use, they need to be swung up out of the way, so most are hinged. Although U.S. Safety Standards and Regulations do not require chuck-shields to be electrically interlocked, some European manufacturers offer that feature. With electrically interlocked shields, when the lathe chuck shield is lifted up, the positive contacts on the microswitch open, sending a stop signal to the machine control. The machine will not start up again until the emergency stop button has been reset.

Another type of protection commonly used on lathes is a chip/coolant shield. These are often useful when the operator’s personal protective equipment (PPE) does not adequately control the waste product coming off of the cutting tool. If chips strike the operator in the upper body or accumulate on the floor creating a slip-trip hazard, a chip/coolant shield is often suggested to supplement the operator’s PPE. OSHA’s 1910.219 addresses the need to cover rotating components to prevent the operator’s hair and clothing from getting entangled, dragging them into the machine. These rotating components include the lead screw, feed rod, traverse rod, and camshaft, in the lower front portion of the lathe.

In April 2011, a lathe’s horizontal rotating components took the life of a 22-year old female student at Yale University’s Sterling Chemistry Laboratory. While working very late at night by herself, her hair became entangled in that part of the machine, resulting in asphyxiation. (Google; Yale Lathe Fatality)

Telescopic metal sleeves are available to cover a lathe’s horizontal rotating components, although many manufacturing companies elect not to use them. According to feedback from OSHA Compliance Officers and Insurance Loss Control Inspectors, one of the most common lathe accidents results from the misuse of the standard chuck wrench furnished by the lathe manufacturer.

When the lathe is not being used, a typical (unsafe) storage place for the chuck-wrench is in the chuck. At some point in time, the operator turns the lathe on without checking to see where the chuck wrench is located, which sends it flying. This has caused serious accidents, including the loss of eyes. Spring-loaded, self-ejecting chuck wrenches are a solution to this problem because they won’t stay in the chuck by themselves. They are available in a number of sizes.

Many older lathes also need updates to bring them up to code with electrical standards like NFPA 79. The two most common updates are for: 1) magnetic motor-starters to provide dropout protection, (a.k.a. anti-restart), and 2) main power disconnects that lock only in the OFF position. As with any machine, provision for Lockout/Tagout is always important.

Danger and Warning signs, depicting specific hazards on lathes are also available.

To see these and other lathe safeguarding products, please call 1-800-922-7533 or visit our website.