safety director on steroids

[billk554]

we have a new director who wants machines locked out before working on them. great point. now the problem. if an operator uses the installed safety's (open a cover on a machine to clear a jam) the installed safety's function shuting down power to make entry to the area and clear out stuff. the safety director notices a light on on the machine and says the machine is not safe to work on becaused there is still electricity going to the machine. its the same when we push the stop button but the button is illuminated so he sees the light and says the machine still has power to it lock it out. now the operators are not doing any electrical work, they are just clearing a jam. the installed safety's are functioning, there is no danger of any other type of stored energy, where are the standards listed to define the duty of safety switches and their purpose?
by the way . . .does anyone need a new safety director?

 

[WorkSafe]

The operator doesn't require LO/TO IF:


OSHA 1910.147

Note: Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).

Saying this, if a jam occurs, that is not a normal everyday thing and in my opinion would need lock out/tagout. The safety device on the cabinet door would not suffice. Someone would need to isolate the machine from it's energy sources.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9804

Servicing and/or maintenance. Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.

 

[Jraef]

... now the operators are not doing any electrical work, they are just clearing a jam. ...

Wait, are you implying it was OK for operators to do electrical work if the machine was not locked out? I think if that's the case, your Safety Director is doing his/her job!

 

[renosteinke]

"Back in the day" when they were first inventing this 'safety' business, you had two sources for safety professionals: there were those from insurance backgrounds, and those from the very few 'safety engineering' backgrounds. Oddly enough, as this new field developed, it became clear that 'safety' was far more dependant on management accountability than on any specific set of rules, procedures, or piece of equipment.

For most firms, "Safety Director" became a dead-end career path for the least desired entries into the 'management' ranks. Think of it as the place they put the ones that even HR didn't want, but the company needed to have to meet some statistical requirement.

My employer has recently added to their 'safety staff' a fresh-from-school graduate of a 'safety management' program. In reviewing the curriculum of his school, I found almost no mention of codes, standards, or technical training. Instead, I saw all manner of accounting, basic statistics, and a lot of 'set up a training course' and 'documentation' courses. We've got a paper-shuffler who can't ever be a production lead!

I shudder at these 'safety pros' just as much as I shudder at the 'seminar experts' we must tolerate (and subsidize). We've got folks whose training is best compared to that of the itenerant preacher, only they use 1910 as their 'bible.' Their entire focus is not only on regulatory compliance - it's on expanding regulatory scope. In place of reality, they have doctrine. In place of solving problems, completing tasks, and producing things, their focus is on setting up a self-perpetuating bureaucracy.

Let's face it: we have the inmates running the asylum.

 

[WorkSafe]

And then we have the folks who blatantly put themselves or their coworkers in jeopardy by not complying with regulations or policies meant to make them safe and go home to their families.

Reno,

Not sure what your rant has to do with the OP's question.

 

[renosteinke]

It can be a fine line between a rant and an explanation.

I was asserting that not only do I suspect the 'safety guy' in question was a loose cannon, I was asserting that the entire system is designed to ensure the 'safety guys' are incompetent - AND that it has nothing to do with safety.

Pretty bold and sweeping - but there it is.

 

[billk554]

no production workers will be doing any electrical work. that should not be implied. whats more is no productions workers were ever issued a lock or a tag. they are unqualified persons. we will have to go out and lock out their machines so they can clear a simple jam, normal operations of these machines, some times they jam and need to be cleared out. another issue is that two safety's are used, 1:a pull cord to stop the machine and 2:the safety on the door when opened the machine cant start. so 2 safetys have to be in place before the machine starts. 1: the pull cord has to be reset manually and the door must be closed for the machine to start, it wont restart automatically the start button has to be pushed. i believe the safety's in place are enough its just a director who doesnt understand things

 

[WorkSafe]

A loose canon? It's federal law that the employees need to lockout the machine to unjam it and the safety director was doing what he was hired to do.

It would be my opinion that the operator of this machine is a loose canon and large liability for the company.

An amputation or death in the company as a result of someone not following LO/TO could easily bankrupt and shut down the place, so having someone, whether it be a safety director, specialist, or other person find these violations is a good investment, I mean, that is if you care about your employees of course.

 

[hurk27]

I have seen over the years to many workers loose fingers, arms, and even their life because of no LOTO in place at the time.
I worked at a company that made fiber products once in the 1970's and some of these machines would eat you up, we had shears that would cut a 80" wide web of material faster then you could blink your eye, fiber blenders with spikes as big as your pinky on drums spinning fast, vacuum condensers so loud you never would know which machines were running or not unless you can see something moving.

The problem is depending upon a push in stop station to make the moving parts of a machine safe is a very false sense of safety, contactors have been known to energize a motor on its own when the return spring fails, maintenance guys not knowing that some one is working on a machine has been known to manually push contactors in to test why the machine has stopped, jumper between point in the control for the same reason.

and the above is why we lost a worker, he had a fiber jamb in a large web machine which he hit the stop station, and climbed in the back of it to clear out a jamb, no one knew he was in there and the line foreman didn't know where he went as it was common for a worker to run to the bathroom, the line foreman turned the machine back on, till the results started coming out in the fiber web.

in my case I had a in-feed conveyor for a blender jamb, and I even tagged out the disconnect for it, the operator who couldn't read English riped out my tag and turned on the blender, ripping up my right arm, I got lucky as all it did was open up the skin, but didn't do and internal damage, but it could have been worse.

The fact that the OP said he had to remove a cover told me the area he was accessing may be a dangerous area if the machine was turned on, I would never depend on just hitting a stop button in if this is the case, why do you think the NEC went to the trouble of requiring disconnects within site of motors?

 

[pfalcon]

A loose canon? It's federal law that the employees need to lockout the machine to unjam it and ...

Try referencing that. You won't find such a law.

LOTO is not mandatory for relieving a jam.

Typically the first jammed part requires LOTO as part of the evaluation of the problem. Afterward a written SOP can be established for removing the jam. Door interlocks, "6th fingers", and other aids can be used in place of LOTO if appropriate to the jam condition. Each jammed part is different. Some must be relieved under machine operation in which case all safeties must be in place with no LOTO at all. Others require LOTO and millwrights with wrenches to relieve.

This case cannot be evaluated without a good engineer going through the prints and physically looking at the machine and jam conditions.

So to the OP, LOTO is probably required until a qualified engineer evaluates the jam condition and establishes a proper Standard Operating Procedure for relieving the jam. The SOP is not likely to require LOTO.

 

[WorkSafe]

Try referencing that. You won't find such a law.

LOTO is not mandatory for relieving a jam.

I referenced it in a earlier post. Please read.

 

[billsnuff]

I think it requires LOTO

I think it requires LOTO

1910.147(a)(2)(ii)(B)
An employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle.

Energy isolating device. A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: A manually operated electrical circuit breaker; a disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors, and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy isolating devices.

This is a link to the OSHA LOTO Standard........

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9804&p_table=STANDARDS

At the very least LOTO should apply until a Risk Anaylsis is completed. Control circuits with lockable stop buttons do not comply with 1910.147. At my location,
every task requires a lock out, removing all stored energies until a a Task Analysis is completed and training is conducted which will define 'authorized' and 'affected' personnel. See the definitions in 1910.147.

 

[pfalcon]

OSHA 1910.147
...
I referenced it in a earlier post. Please read.

Yes, I saw this. And I have actually read 1910.147

Example: 6th finger
A snappable reach extender that can be used to push a stuck part on a conveyor without entering the hazardous area.
Since the operator is not exposed, LOTO is not required.

Special handtools for placing and removing material shall be such as to permit easy handling of material without the operator placing a hand in the danger zone. Such tools shall not be in lieu of other guarding required by this section, but can only be used to supplement protection provided.

Hence the 6th finger is an alternative to using LOTO to unjam a part.

 

[WorkSafe]

Yes, I saw this. And I have actually read 1910.147

Example: 6th finger
A snappable reach extender that can be used to push a stuck part on a conveyor without entering the hazardous area.
Since the operator is not exposed, LOTO is not required.



Hence the 6th finger is an alternative to using LOTO to unjam a part.

You are throwing up a smoke screen. The OP said his folks are going into the machine and unjamming. Nothing in his post does it say they are using a device that keeps the employee guarded by location.

 

[renosteinke]

Pure balderdash .... that leads back to the 'loose cannon' issue.

Simply put, the 'safety professionals' being created are not trained, or qualified, to make the decisions or develop the procedures. They know not the production operations nor the maintenance issues.

Code reference? Sure, let's leave it to the wordsmiths. Let's look at a typical production operation:

A machine does something to a part. The cycle over, the operator opens the guard, opens the work-holding device, removes the part, places the next part, closes the clamps, closes the guard, and tells the machine to cycle again.

There are a variety of 'protections' for the operator. Everything from control placement to various interlocks that prevent the machine from cycling. Nowhere do we see the operator going to the electrical room and locking out the breaker feeding the machine. Nowhere do we see the operator going to the air compressor and bleeding the pressure from the machine supply lines. Etc. Nor is he required to. You might as well expect someone to let the air out of their tires if they want to scrape a bug off the windshield.

Returning to the OP, "clearing a jam" can mean many things. There are a great many production operations that do not warrant a complete LOTO. Statue has been cited that recognizes this.

The question arises: who is qualified to make the decision? My point is that -especially considering the training that 'safety managers' do NOT get from their schools- the 'safety' guy is likely the least qualified person on the payroll.
That's why I believe the system is out of control.

There is the matter of bias each of us brings to the table. I expect the 'safety pros' to take umbrage .... but I have seen (and the academics have documented) far too many examples that support my bias.

 

[WorkSafe]

reno,

Stop with your rhetoric. You make blanket statements like all safety professionals are untrained. For me as an example, I went to school for 4 years and earned my degree in Occ Safety & Health and been working in the field for the last 11+ years and I can almost guarentee you that I am more knowledgeable then yourself when it comes to industrial safety and the safety field.

Reno, if you are so sure that you can determine if LO/TO is required, then why don't you call OSHA and have them come out and do an inspection for you?

 

[billsnuff]

reno, I agree with your position to the extent that I wouldn't be able to walk in the OP location and tell them what is right without some training on their processes.

That said, and more to the OP, you, as an electrician, should be a 'qualified' individual provided you have been trained (see NFPA 70E). The same is true for the operator, for the tasks he is required to perform, he must be trained to become an 'authorized' person. (see 1910.147) Both require training.

 

[pfalcon]

You are throwing up a smoke screen. The OP said his folks are going into the machine and unjamming. Nothing in his post does it say they are using a device that keeps the employee guarded by location.

The OP never gave us specifics for his machine, nor would I expect him to do so. "Going into the machine" and "Unjamming" can mean a whole host of different content. Which is why I specified a qualified engineer needs to get involved, look at the prints, look at the machine, look at the work, look at the jam :: then determine the proper Standard Operating Procedure to unjam the parts.

I did not write that the OP was using any devices; only that devices are a possible alternative to LOTO.

Until the SOP is provided, which may also require devices, PPE, or machine modification; then LOTO may be the only current method available.

 

[wtucker]

My 2 cents:

Start with 1910.5(c)(1) "If a particular standard is specifically applicable to a condition, practice, means, method, operation, or process, it shall prevail over any different general standard which might otherwise be applicable to the same condition, practice, means, method, operation, or process."

.212 you cited is a general standard. .147 is particular. .147 clearly covers "servicing and maintenance," which includes "cleaning or unjamming of machines or equipment... where the employee may be exposed to the unexpected [emphasized in bold type in the original] energization or startup of the equipment or release of hazardous energy.

"1910.147(a)(2)(ii) Normal production operations are not covered by this standard... Servicing and/or maintenance which takes place during normal production operations is covered by this standard only if:

"1910.147(a)(2)(ii)(A) An employee is required to remove or bypass a guard or other safety device..."

On the one hand, it sounds to me like the interlock is the safety device, and the employee is not required to bypass it.

I'm a Certified Safety Professional with 30 years' experience, and 15 years' experience as an EMT on top of that. Regulations be hanged, the real issue is, what's the likelihood that some unfortunate is going to lose a body part if that switch fails open? Can that be prevented by having an engineer design a lockout point? I side with the body part the worker stands to lose. Lock it out. Unless it's piecework, the worker will be paid just as much for clearing the jam with the lockout on as he will churning out widgets. If the super complains, blame the safety guy. We're used to it.

 

[S'mise]

like hurk27 said

like hurk27 said

Hurk27 said it perfectly. When my arm is in a machine I do no trust the e-stop button, the door interlock or the eng that looked over the prints and deemed it "safe" to go in. I lock out not at the estop button but at the main power. Then test to make sure its dead. How do I know some bozo isnt pushing relays or motor starters in the panel? How do I know the prints are acurate? Bottom line trust no one but yourself.