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. 

Safety Engineering

October 22, 2019 in Safety, Safety Engineering

The California Board for Professional Engineers, Land Surveyors, and Geologist does not mandate a license for those of us who conduct safety engineering.  So how do we justify calling ourselves safety engineers.

To put the controversy to rest we submit the following legal definitions:

Safety Engineering – California Code of Regulations Title 16, Division 5, §§400-476 “…is that branch of professional engineering which requires such education and experience as is necessary to understand the engineering principles essential to the identification, elimination and control of hazards to people and property; and requires the ability to apply this knowledge to the development, analysis, production, construction, testing, and utilization of systems, products, procedures and standards in order to eliminate or optimally control hazards. The above definition of safety engineering shall not be construed to permit the practice of civil, electrical, or mechanical engineering”

Since there is no requirement for licensing of a safety engineer, qualification for the title must rely on meeting the above definition. Such experience goes hand in hand with the legal definition of who is an expert, as noted next.

Expert – Federal Rules of Evidence – Rule 702 – defines an expert witness as a “witness who is qualified as an expert by knowledge, skill, experience, training, or education…” 

Expert –  Blacks Law Dictionary defines an expert as “One who is knowledgeable in specialized field, that knowledge being obtained from either education or personal experience” with a further definition, “One who by reason of eduction or special experience has knowledge respecting a subject matter about which persons having no particular training are incapable of forming an accurate opinion or making a correct deduction”. 

These recognized definitions are all consistent with the requirements of a safety engineer. Though it may be obvious, it is important to state that a safety engineer is limited to doing safety engineering within their field of experience, knowledge and training. Someone who does safety engineering related to medical facilities may not necessarily qualify to provide safety engineering related to aviation unless that person has the same level of knowledge in both fields.

Pacific Injury and Safety Experts, with nearly 49 years in the fields of construction, general industry, insurance, and personal injury is confident that the definition of safety engineering applies to our services and we look forward to providing those services to our clients.

Walkway Safety Certification

September 16, 2019 in ASTM, ASTM F2948-13, Bio-mechanical, certified auditor, Certified walkway expert, Gate mechanics, Human gait cycle, Walkway hazards, walkway safety

On September 12, 2019 The University of North Texas, Department of Engineering Technology, awarded our Senior Expert, Gidon R. Vardi, Ph.D, the certificate of completion in Walkway Safety Certification.

Among others, the certificate acknowledges that Dr. Vardi has completed a course in walkway safety which includes meeting the qualification requirements of ASTM International Guide F2948-13 for walkway auditor, meeting the requirement to be considered a “qualified person” by the Occupational Safety and Health Administration (OSHA). 

Certification provided training in how to interpret and use tribometer readings to evaluate walkway safety, identify, suggest remediation for, and offer resolution for slip, slides and fall hazards on walkways, apply the principles of walkway safety, slip prevention, and risk assessment to comprehensive walkway safety management programs. Training includes background in bio-mechanical human gait cycle and gait mechanics.

Why Does Fall Protection Count?

August 28, 2019 in Cal/OSHA, Fall Protection, 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, Fall Protection, Falls, Hazard, Injury, OSHA, Safety

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.