The Occupational Safety and Health Administration (OSHA) provides the top ten violations cited for each year, and machine guarding, and the control of hazardous energy are always on the list. The wood container and pallet manufacturing industry accident statistics have a direct correlation with these two violation categories.
In my experience, catch points or pinch points on machinery are some of the most common hazards found. Quite often these hazardous exposures are due to lack of guarding at the point of operation, guarding being removed at the point of operation, or failure to control hazardous energy during maintenance and repair. Lack of safety training on these subjects is frequently a factor that may result in an accident.
In review of an OSHA compliance inspection of a pallet plant fatality that resulted in over $177,000 in proposed penalties after a fatality, OSHA also cited the company for 15 serious violations for lack of point-of-operation and machine guarding on table saws, band saws, shaft ends, chains and sprockets.
The following general requirement 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 types of guarding 1, 2 and 3 pretty much cover every type of point of operation and guarding requirement. In other words, 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. A common point of operational exposure is directly related to a machine’s motions and actions.
Examples of point of operation exposures to machinery’s hazardous motions and actions:
Motions:
- Rotating
- In-Running Nip Points
- Reciprocating
- Transversing
Actions:
- Cutting
- Punching
- Shearing
- Bending
The Occupational Safety and Health Administration (OSHA) requires that all machinery and power-operated tool points of operation be guarded, when that point of operation exposes employees to injury.
Machinery and or power operated tool points of operation include:
- Area on a machine where work is actually performed upon the material being processed.
- Pinch points and catch points
- Reciprocating, rotating or moving parts
- Energy source contact points
Common machinery and power operated tool components that require guards:
- Power driven blades, shafts, sprockets, spindles, flywheels, gears, pulleys, abrasive wheels, belts and chains
The following are some of the machines which usually require point of operation guarding:
- Pallet grinders and choppers
- Nailing machines
- Table saws
- Shears
- Power presses
- Milling machines
- Lathes
- Power saws
- Jointers
- Portable power tools
- Forming rollers
OSHA standards require that guards 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.
When power operated tools are designed to accommodate guards, they shall be equipped with such guards when in use. Unfortunately, not all machinery and power-operated hand tools come with the point of operation are properly guarded. In these cases, the employer is required to guard the machinery or power-operated tool.
One common question is, “How big of an opening can cause a catch or pinch point?” While that can vary depending on the size of the body part of the operator, usually a good rule of thumb is ¼ inch for presses and grinders and ½ inch for blades, bearings or conveyor components. Also, it is important to be aware of things that can easily become entangled in equipment, such as long hair or loose clothing. That’s why it is always the safest practice to have tight-fitting, tucked-away clothing and hair while working around machinery and power tools.
One tool you can use to measure distances and openings for machinery is an OSHA guard opening scale. These are sold on Amazon and other online stores for under $100. An OSHA guard-opening scale is a valuable tool to use during the design, installation, and inspection of guards to make sure they comply with OSHA safety standards.
Generally, guarding must be designed and constructed to prevent the operator from having any part of their body in the danger zone, or point of operation, during the operating cycle.
Common types of guards include:
- Barrier guards
- Tripping devices
- Electronic safety devices
Guarding Examples:
One of the most common guarding violations is an improperly guarded bench grinder. Bench grinders can be found in nearly every industrial workplace.
Figure #1 shows a new bench grinder that is missing guarding, and figure #2 is a close-up photo of a properly guarded bench grinder.
OSHA Standard for abrasive wheel machinery is 29 CFR 1910.215, and in the standard the following guarding reference (figure #3) is shown;
As shown, the abrasive wheel grinder must have a top guard (tongue guard), a bottom rest guard, an abrasive wheel flange guard, and a spindle guard. All power operated tools and machines designed for a fixed location must be securely anchored to prevent walking or moving while in operation.
Angle-head grinder
Figure #4 shows an angle-head grinder that is missing guarding, and figure #5 is a photo of a properly guarded angle-head grinder.
Barrier guarding for hazardous areas and zones:
Many times, the point of operation is a large working area, and standard guarding is not practical. In these cases, barrier guarding may provide the best protection to workers. This is important to remember when screening is used in barrier or point of operation guarding. The closer the barrier guarding is to the point of operation, the smaller the gaps in the screen. This prevents the employee from placing any body part in the point of operation. See figures #6 and #7 for examples of barrier screening gaps and barriers.
Power driven shafts, sprockets, spindles, flywheels, gears, pulleys, belts and chain guarding.
Power driven machinery will almost always have shafts, sprockets, spindles, fly wheels, gears, pulleys, belts and/or chains. This is always the case for in-feed and out-feed chains, rollers, belts, and conveyors. See figure #8. Therefore, any point in which a body part can become entangled, caught or pinched must be guarded.
Drive belts on power driven machinery must be guarded at both the front and back. See figure #9 Points of operation on lathes must be guarded as in figure #10.
Remember to use the Hierarchy of Control as a guide in the reduction of hazards:
Hierarchy of Control:
- Elimination (Eliminate the hazard)
- Substitution of less hazardous materials, processes, operations or equipment
- Engineering controls (Guarding / barriers)
- Warnings (Signage)
- Administrative control (Policies, procedures, and training)
- Personal Protective Equipment (PPE)
Control of Hazardous Energy / Lockout – Tagout:
OSHA standard for The Control of Hazardous Energy (Lockout and Tagout), 29 CFR 1910.147, requires that hazardous energy be controlled during service and maintenance activities. These activities include the installation, setup, adjustment, inspection, modification, and routine maintenance or servicing of machines or equipment.
Many accidents occur when the hazardous energy of a machine is not isolated during maintenance and repair. Lockout – Tagout must be performed on a machine when panels, or guards, would need to be removed while repairing equipment or when you would be placing any body part near the equipment’s point of operation. Equipment that can start automatically and/or have stored energy, such as an air compressor, requires that the energy sources be isolated during maintenance or repair.
Training:
An employer can have all of the safeguards in place that will physically prevent an employee from coming in contact with the point of operation of equipment, but these engineering controls are useless without employee safety training. Employees must receive safety training relevant to the hazards related to the job tasks they will be performing. This must be completed at their initial hire and at least annually thereafter. Safety training must also include those related OSHA standards, such as the Control of Hazardous Energy Standard.
For reference on the laws for guarding machinery. you can find the information in the following OSHA Standards:
OSHA Standards for general machinery guarding can be found in 29 CFR 1910.112
OSHA Standard for woodworking machinery guarding can be found in 29 CFR 1910.213
OSHA standard for The Control of Hazardous Energy (Lockout and Tagout), 29 CFR 1910.147.
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@gmail.com.
