safety director on steroids

[petersonra]

It is quite possible to safely unjam certain things without LOTO. LOTO is only required if the work involved exposes the operator to some hazard.

often times minor redesigns of equipment can make correcting jams a lot easier and safer.

sometimes it is as simple as using a push stick instead of a hand, although I have heard it opined that this is unsafe because the stick might get caught in the machine and pull the operator in because he is too dumb to let go.

 

[pfalcon]

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. ...

You have that backwards. 1910.212 belongs with Subpart O "Machinery and Machine Guarding" which is more specific than 1910.147 Subpart J "General Environmental Controls".

 

[wtucker]

You have that backwards. 1910.212 belongs with Subpart O "Machinery and Machine Guarding" which is more specific than 1910.147 Subpart J "General Environmental Controls".

Nope. Even though the title of Subpart J says "General," we have to read the scope and applications of the standard, as well as any exclusions and definitions that might be included.

1910.212, titled "General Requirements for All Machines," discusses types of guarding, general requirements, point of operation guarding; revolviing barrels, containers, drums; blades and machine anchorages.

1910.147 quite specifically "covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy." There is an assumption, in .147(a)(2)(ii), that guards, required during normal operations, would have to be removed or bypassed during servicing and maintenance. .147 specifically does not cover normal operations.

 

[iwire]

reno,

Stop with your rhetoric.

Not going to happen, I have been asking him that for years. :grin::grin:

 

[dconrad]

Loto

Loto

I worked for a large wood products firm, we put knife disconects on our machine centers and on the larger centers we would gang them and use a cable then a gang lock. That way all power to machine was disconnected also made up a sheet showing what needed to be locked out. Once everyone got used to it, it was fast and easy to lock the equipment out. Dont forget the most important part. TEST to see if it will start.

 

[pfalcon]

Nope. Even though the title of Subpart J says "General," we have to read the scope and applications of the standard, as well as any exclusions and definitions that might be included.

Subpart O titled "General Environmental Controls"
Subpart J titled "Machinery and Machine Guarding"

Actually, no you don't get to do it that way. Once the scope is limited by the subpart you don't get to expand it by a subpart of a subpart. Further:

This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy.

Normal production operations are not covered by this standard (See Subpart O of this Part). Servicing and/or maintenance which takes place during normal production operations is covered by this standard only if:

An employee is required to remove or bypass a guard or other safety device; or

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.

147 is minimum performance; 212 requires additional performance and is therefore more restrictive.

Service/Maintenance only qualifies for this section IF:
A) Bypassing guards or B) Sticking body parts inside.

Get your engineer out there to DESIGN the guards properly so that they don't have to be bypassed nor require reaching in; then you don't have to lockout. Which is exactly what a "6th finger" does. It permits the guards to remain in place and substitutes for body parts. Then 147 no longer applies but 212 still applies; because 212 is more specific with additional requirements.

If you're unwilling to design it correctly then there's no hope for you anyway. Lock it out.

 

[wtucker]

For safety's sake, I agree that safe design is paramount.

As to interpretation of the standards, you and I can argue 'til the cows come home, but the only interpretation that really matters is the local OSHA Area Director's. Even if he or she is wrong, it's going to cost the employer a boatload of money to contest the citation. You and I can take our respective cases to the AD, then to the solicitor, then see what the administrative law judge says.

 

[pfalcon]

:grin: So true. And I doubt the AD or the Admin Judge will have spent anytime on a forum testing their views for weakness. Be safe.

 

[wtucker]

Weakness? I'd be happy if they tested their views for credibility!