Removing or disabling safety guards may seem like no big deal. But one pallet manufacturer in Ohio discovered the dangers associated with this action earlier this summer. A teenage employee lost his hand when it got caught in a planer where the safety guards had been removed. This and other safety violations led to the company being cited by Occupational Safety and Health Administration (OSHA) for $43,200 in fines.
Safety guards exist for a reason, and removing them can lead to loss of life, injury and fines. No production gain is worth that cost. Machinery guarding, or the absence of guarding, is a common OSHA violation. During workplace safety assessments, it is not abnormal for me to find a list of guarding issues, or point of operation exposures, when inspecting a new workplace.
Machinery guarding issues are a top concern for OSHA. Of the 4405 fatalities recorded in 2013, 131 were due to a person being caught in or compressed by equipment or objects and 105 were due to a person being caught in running equipment or machinery.
During a recent inspection of a manufacturing facility, I brought their attention to a stationary tool that was improperly guarded. The horizontal shaft, or the point of operation, had a four inch access point, at which a person could easily place their hand in, and become entangled. The safety committee that was accompanying me with the inspection became silent, and when enquiring why, they stated that they were the manufacturer of that device. They had no idea that their own equipment was improperly guarded. This little detail may have saved them a costly lawsuit.
Case in point; a company can purchase a brand new tool, and it may not meet OSHA Standards right out of the box. A very common guarding standard violation is missing guarding on a bench or pedestal grinder. An abrasive wheel grinder is like a magnet for an OSHA compliance officer. An abrasive wheel grinder must have a top guard (tongue guard), a bottom rest guard, an abrasive wheel flange guard and a spindle guard.
If the machinery has open gears, shafts, chains, sprockets, pulleys, or belts, these points must be guarded. Guarding is also required, if a worker can be pinched, caught, or become entangled in the machinery. All hazardous exposure points must be guarded.
Accidents due to unguarded points of operation are not uncommon in the wood products industry. Although there has been huge improvements in that last 30 years, there are many points of operation that cannot be guarded to the point to sufficiently prevent someone from becoming entangled if a hand is placed in the wrong location. That is where safety training and warning signs can make all the difference.
One of my first woodworking accident investigations involved an in-feed conveyor. A drive sprocket and chain at the beginning of the in-feed conveyor for a molder had not been guarded. A male worker was feeding the molder at that position. The worker had a loose jacket on, and while leaning over the conveyor to reach a piece of material, his jacket became entangled. The jacket material began to twist on the sprocket shaft as it turned. Another worker saw what was happening when the worker screamed, and was able to shut the conveyor off. The workers sleeve had twisted to the point the worker’s neck was pulled down to the in-feed, and was tightening the jacket’s collar around his neck. The worker was only a few seconds from being strangled, when the conveyor was shut down.
It is still common to see this very guarding issue on conveyor systems. Either the guard was never installed, or never re-installed after maintenance had removed it.
Another very common point of operation guarding issue found, is that the employer has taken every step possible to guard the front of a piece of machinery, but has not made any attempt to guard the back side of the machinery.
A good example is this component saw in figure #1. As you can see the front of the saw is guarded with expanded metal, yet around the side of the saw, it is completely open. (See figure #2). A worker could very easily reach into the point of operation through this large opening.
Here is an example of inadequate point of operation guarding. The employer had made an expanded metal guard for the rear of this saw. Not only is the guarding inadequate, but the operator had turned the guard into a holder for his clipboard. See figure #3.
In previously mentioned saw guarding issues, the ruling is quite simple:
OSHA Standard 29 CFR 1910213 (a) (12)
For all circular saws where conditions are such that there is a possibility of contact with the portion of the saw either beneath or behind the table, that portion of the saw shall be covered with an exhaust hood, or, if no exhaust system is required, with a guard that shall be so arranged as to prevent accidental contact with the saw.
The best rule for guarding, is to have as little space possible between the sawblade, and an adjustable guard. Adjusting the guard to 1/4 inch of the material will reduce the exposure to the blade. Most every small bandsaw I inspect, vertical or horizontal mount, has an improperly adjusted guard, as in figure #4
Manufacturers of band resaws, and bandsaw style pallet dismantlers are providing point of operation and power transmission safeguards as standard equipment. Drive components such as; feed rolls, gears, belts, pulleys, chains, bandsaw wheels, guides, catch points and pinch points are no longer exposed. Older equipment may not have safe guards manufactured into the equipment, and in those cases, the employer needs to guard all points of operation.
Unfortunately, the human factor cannot be completely guarded out. You can guard nearly every point of operation exposure, but the saw by design, must have the working area to cut material. When there is potential for human contact, you must guard that point of exposure. Potential hazards exist behind equipment, along the sides, above and beneath.
And this is where proper instruction and training must be done to ensure that workers keep their hand away from moving parts and the blade. Machinery workers must be made aware of safe operating distances and best practices, such as using a push bar when items get stuck.
I remember some years back a worker had found that crossing the in-feed of a saw was the fastest way around the equipment. This particular in-feed was below waist level, and a tall person could step over it. Unfortunately, this is where the human factor prevents standard guarding from being effective. This worker had grown too accustomed to crossing the in-feed, and due to never being reprimanded, it became a dangerous everyday habit. One day, his luck ran out, and he tripped while crossing the in-feed, and his leg was pulled into the saw.
Where electronic barriers, and other automatic safe guards are not in-place or feasible, safety railing, mesh or plastic barricades, or expanded metal barriers may be the easiest guarding option to keep workers clear of equipment. Obviously, the guarding must be left in-place, unless all hazardous energy has been isolated, and the machinery has been locked and tagged out.
In cases where tables or working surfaces are the only barrier that can be in-place, it is always a good idea to install warning labels or paint those hazardous areas with a bright color to continually remind workers of the potential hazard.
When other engineering controls can’t eliminate an exposure to hazardous points of operation, then guarding must be put into place. Even with guarding, you must provide documented safety training. Due to the human factor, without training, a worker will remove a guard or fence, and think they can reach into it, just one time to get something cleared, and that is all it will take to have a serious injury or fatality.
Then in other circumstances, an employer may allow a worker to continue such hazardous practices as reaching into an area of the point of operation. Then, when there is an accident, the employer had knowledge of the hazardous practice, but allowed it to continue. Penalties for willful negligence can be very costly, and of course, there is no higher cost, than a worker’s life.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@aol.com.
OSHA Guarding Regulations
Review OSHA standards for general machinery guarding (29 CFR 1910.112) and
OSHA standard for woodworking machinery guarding (29 CFR 1910.213 )
The following general requirements for all machinery is taken from the OSHA Standard:
1910.212 General Requirements for All Machines.
(a) Machine guarding.
(1) Types of guarding. 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. Examples of guarding methods are – barrier guards, two-hand tripping devices, electronic safety devices, etc.
(2) General requirements for machine guards. Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself.
(3) Point of operation guarding.
(i) Point of operation is the area on a machine where work is actually performed upon the material being processed.
(ii) The point of operation of machines whose operation exposes an employee to injury, shall be guarded. The guarding device shall be in conformity with any appropriate standards therefore, or, in the absence of applicable specific standards, shall be so designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle.
(iii) Special hand tools 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.
The OSHA Standard 29 CFR 1910.213 Woodworking Machinery Requirements, provides the guarding requirements for various woodworking machinery. The standard has specific instructions for the following woodworking machines:
1910.213 Woodworking Machinery Requirements.
(a) Machine construction general.
(b) Machine controls and equipment.
(c) Hand-fed ripsaws.
(d) Hand-fed crosscut table saws.
(e) Circular resaws.
(f) Self-feed circular saws.
(g) Swing cutoff saws.
(h) Radial saws.
(i) Bandsaws and band resaws.
(j) Jointers.
(k) Tenoning machines.
(l) Boring and mortising machines.
(m) Wood shapers and similar equipment.
(n) Planing, molding, sticking, and matching machines.
(o) Profile and swing-head lathes and wood heel turning machine.
(p) Sanding machines.
(q) Veneer cutters and wringers.
(r) Miscellaneous woodworking machines.
(s) Inspection and maintenance of woodworking machinery.
