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OSHA

Machine Guarding

January 3, 2020 in Hazard, Injury, Machine Guarding, OSHA, Safety

Industrial and manufacturing plants and assemblies are closely associated with machine guarding as an element for protection of workers and those around them.

Machine guarding is one of the essential elements that concerns industrial and manufacturing plants. Machines that fall into the category of guillotine cutters, shears, alligator shears, power presses, milling machines, power saws, jointers, forming rolls and calendars, and various portable power tools are just some of the basic machines that require guarding. 

In California Cal-OSHA machine guarding requirements are found under Subchapter 7. General Industry Safety Orders, Group 8. Points of Operation and Other Hazardous Parts of Machinery 

Article 54. Scope and General Definitions, Section 4184 which states the following:

(a) Machines as specifically covered hereafter in Group 8, having a grinding, shearing, punching, pressing, squeezing, drawing, cutting, rolling, mixing or similar action, in which an employee comes within the danger zone shall be guarded at the point of operation in one or a combination of the ways specified in the following orders, or by other means or methods which will provide equivalent protection for the employee.

(b) All machines or parts of machines, used in any industry or type of work not specifically covered in Group 8, which present similar hazards as the machines covered under these point of operation orders, shall be guarded at their point of operation as required by the regulations contained in Group 8.

Exception: Microtomes (also called histotomes or cryostats) when guarding as required in Section 4184 is infeasible and the microtome is used, operated and maintained in accordance with Section 3558 of these Orders. For the purposes of this Exception guarding as required in Section 4184 is infeasible under circumstances that include, but are not limited to the following: there is no point-of-operation guard commercially available for an employer’s microtome.

Note: Authority cited: Section 142.3, Labor Code. Reference: Section 142.3, Labor Code.

Similar language is found in the United States Department of Labor Occupational Safety & Health Administration guidelines for machine guarding Section 1910.212(a)(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.

It is important to note that machine guarding alone is not sufficient when maintaining any equipment.  Proper Lockout, Tag-out, or Block-out protocol must be followed.  A July 2019 publication by Cal-OSHA noted the following:

Failure to lockout, tag-out, and block-out (LOTO) machinery before working on it is a major cause of serious injuries and deaths. Workers can be electrocuted, suffer severe crushing injuries, and lose fingers, hands, and arms because machinery is inadvertently turned on while it is being cleaned, repaired, serviced, set-up, adjusted, or unjammed.

(For more information see Cal-OSHA Subchapter 7. General Industry Safety Orders, Group 2. Safe Practices and Personal Protection, Article 7. Miscellaneous Safe Practices Lockout / Tag-out / Block-out, Section 3314)

The author started to work with heavy machinery dating back to the early 1970’s.  The nearly 50 years of hands on experience, numerous installations, and scores of investigations, in addition to certifications and licenses, has provided the type of experience that allows the author to provide expert opinions regarding machine guarding and other industrial safety topic. 

Why Does Fall Protection Count?

August 28, 2019 in Cal/OSHA, Falls, Hazard, Injury, OSHA, Roof, Safety, Slips

In a perfect scenario as illustrated in the attached photos we see a roofer standing at the edge of a parapet.  The roofer has no fall protection of any kind.  Give the roofer credit for wearing protective clothing necessary as a means to protect his body while applying a coating over a spray foam roof, but that protective suite will not stop him from falling.

The distance from the top of the parapet to the ground is approximately seventeen (17) feet.  The ground below is a hard surface which would be unforgiving to a falling human body.

A slight slip of either feet. A tangling of the boots in the protective covering. A sudden distraction. A sudden gust of wind. All of these situations can cause the roofer to loose his balance and fall to the ground below.

Beyond any OSHA requirement, and the obvious serious injury or even fatality which would result in the roofer falling to the ground below, the shock and grief that will affect to his fellow roofers, family, and friends is beyond measure.

It is for all the right reasons, and logical conclusion, that fall protection is a necessary safety measure. The code allows a number of ways to protect the roofer or anyone else working above ground.  Simple steps can reduce the risk of injury and prevent long term disability and even death.

When Fall Protection Means Saving A Life

Dangerous Behavior

August 13, 2019 in Cal/OSHA, Falls, Hazard, Injury, OSHA, Safety, Signs

It goes without saying that standing in the bucket of an excavator to hang a sign is not a good or safe idea. Such behavior is not only unsafe but also violates California General Industry Safety Orders, §3657 – Elevating Employees with Lift Trucks (Fed OSHA §1910.67). 

According to the United States Department of Labor OSHA (osha.gov) “Many workers are injured or killed on aerial lifts each year”. Currently an aerial lift is described as one of the following:

  • Extendable boom platforms,
  • Aerial Ladders,
  • Articulating (joined) boom platforms,
  • Vertical towers, and
  • Combination of the above

The bucket of any excavator does not fit the definition of an aerial lift.

According to OSHA (osha.gov) even if someone properly uses an aerial lift the hazards for using such equipment may include: 

  • Fall from elevated level,
  • Objects falling from lifts,
  • Tip-overs
  • Ejections from the lift platform,
  • Structural failures (collapses)
  • Electric shock (electrocutions),
  • Entanglement hazards,
  • Contact with objects, and
  • Contact with ceilings and other overhead objects

As illustrated in the photo below the gentleman is hanging a warning sign while standing inside the bucket of an excavator. How ironic that someone is hanging a warnign sign considering the unsafe behavior being exhibited.  

You Should Never Do This

In the instance of hanging a warning sign a safe practice would be to use a properly designed ladder supported by solid footing.  Solid footing in this case would have been a smooth, level, and solid ground.

Solar Panel Installer Falls Through A Skylight

January 25, 2019 in Cal/OSHA, Falls, OSHA, Personal Protection Equipment, Safety, Skylight

Fontana, CA – An investigation of an industrial accident took place on June 14, 2016 concerning an employee who on June 13, 2016 sustained serious injuries after falling to the ground through an unguarded skylight while engaged in solar panel installation. The employee was not protected by use of guardrails, personal fall protection system, cover, screens, nets or any other methods

Cal/OSHA issued five citations to an electric contractor after a 29-year-old solar panel installer fell 29 feet through a skylight, suffering extremely serious injuries. The citations included a willful serious violation of Section 3212 Floor Openings, Floor Holes, Skylights and Roofs which requires employers use fall protections systems to keep employees safe. In this case, the employer did not provide the protection even though the company charged the building owner for it. There was no evidence of fall protection such as guardrails, personal fall protection system, covers, screens, nets or any other methods anywhere in the building, despite the presence of more than 140 skylights on the roof.

All employers in the State of California who are cited by Cal/OSHA are entitled to an appeal of the citations.

We have extensive experience in the investigation and analysis, including court testimony, concerning falls through skylights.

Cal/Osha Cites An Employer For Injuries To Employee Due To Electrocution At A Construction Site

December 30, 2018 in Cal/OSHA, Hazard, Injury, OSHA, Safety

Rialto, CA – Cal/OSHA Reporting ID: 0950633 stated that on or about May 25, 2018, an Electric Crew Foremen became incapacitated when he contacted energized parts of a 6.9kV transformer causing the employee serious injuries.

The Employer was cited, among others, for failing to ensure that a supervisory employee (Electric Crew Foreman) utilized protective coverings or devices, adequate barriers, or isolation methods while working on exposed underground cables, concentric ground wires, or conductors, including but not limited to, equipment or parts of an energized transformer located within a BURD structure having a working space of less than 36 inches. As a result, an employee while attempting to remove an old ground wire came in contact with an energized section of the transformer with an operating voltage of 6.9kV causing the employee serious injuries.

The citation continues to state that prior to, and during the course of the investigation, including but not limited to May 25, 2018, the Employer failed to ensure that a supervisory Employee (Electric Crew Foreman) utilized hazardous energy control procedures or personnel change to ensure the continuity of lockout or tag-out protection, including but not limited to provisions for the orderly transfer of lockout or tag-out device protection between off-going and on-coming Employees, to minimize their exposure to energized parts of a 6.9kV transformer located in a BURD structure.

It is alleged that the Employer failed to ensure that a supervisory employee (Electric Crew Foreman) eliminated all possible sources of back-feed voltages on a 6.9kV transformer (being back-fed by a generator), by effectively disconnecting or grounding the high voltage side, or disconnecting or short circuiting the low voltage side.

Last, the citation alleges that Employer’s Field Supervisor, and an Operations Supervisor failed to immediately call 911 to ensure prompt medical treatment, resulting in unnecessary delay in treatment to an employee who sustained a serious injury. 

In all Cal/OSHA cases the Employer is entitled to an appeal of the citation.