MEMIC Safety Blog

Who is the Authorized Employee for Lockout/Tagout?

  Posted by Henry Reynolds

 

Do you know who your authorized employees are?  Do you have employees performing service and maintenance on machinery without adequate authorized training and exposure controls?

 

Safety consultants often see employees performing servicing and maintenance activities on machinery and equipment without proper lockout compliance because the employer does not see some workers as authorized employees under OSHA's standard for controlling hazardous energy.   Examples are equipment operators, employees helping maintenance personnel, cleaners, lubricators, employees working with contractors, or supervisors evaluating work being performed on machinery. 

 

Here's OSHA's definition of Authorized Employee: A person who locks out or tags out a machine or equipment to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under 1910.147.

 

OSHA's 1910.147 lockout standard requires lockout compliance under the following conditions:  "1910.147 (a)(2)(ii) 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."

 

When evaluating your employees to determine who the authorized employees are, you must consider the terms “servicing and maintenance".

 

Lockout activities are mandatory during "servicing and/or maintenance". These include activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities also include lubrication, cleaning or removal of a jam in a machine or equipment, and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or a release of hazardous energy.

 

 Are your workers performing tasks that require lockout? Are they putting their bodies in harm's way if an unexpected energization of the machine occurs? Are they removing guards? If so, then we must reconsider who the authorized employees are. Failure to do so could lead to serious injury and even death.

 

MEMIC policyholders who need further assistance with your Lockout/Tagout program should feel free to contact your Safety Management Specialist at MEMIC or contact MEMIC Loss Control Department to ask for assistance.

 

Operator's Manuals - Instructions Worth Reading

 Posted By Greg LaRochelle

 

These days, due to the global market and cultural diversity, manufacturers produce operator's manuals in several languages that are often confusing. You either find a folded sheet at the bottom of the box that opens into a poster-size layout of seemingly disjointed instructions, or a virtual tome of information that ends up being cast aside as you begin to assemble the product.

 

Of course, just jumping in knee-deep, in a manner of speaking, can lead to confusion, frustration, spare parts, and sometimes, bodily injury.  I recall a number of years ago, finding a product shipped in a container with a VHS tape that offered instructions on properly opening the container.  Think about that one for a moment.

 

That said, though we may have to skip a few pages to continue with the instructions in our native language, it's always prudent to take the time to read the information, especially any safety precautions that are included.  Usually, this section is highlighted and appears at the front of the manual. 

 

I visited a jobsite for one of my abatement contractors recently and was pleased to see the operation and maintenance manual for the newly purchased infrared floor tile lifter in plain sight.  It was obvious the manual had been "flexed" and reviewed prior to the crew using the machine.  Electrical needs and other safety precautions were clearly defined in the manual. 

 

It turns out that temperature and dwell time over a square of tiles was really important for this machine. Otherwise, the vinyl asbestos flooring could overheat to the point of thermal decomposition, rendering noxious airborne by-products.  Not to mention the potential destruction of material. It paid to read these instructions.

 

So, frustrating though they may be, take the time to read the manual – even if you already know how to open the box.

Lifting: You Can Measure the Risk

  Posted by Bill O’Connor

If you have manual handling tasks at your place of work, don’t keep your workers safe by accident.  All manual handling tasks should be evaluated for risk of injury by considering the force of exertion, frequency, body mechanics, type of load and hand grip, as well as the duration that workers are lifting. 

 

The National Institute of Occupational Safety and Health (NIOSH) has devised a simple tool for making just that assessment.  By taking a few simple measurements of a lifting task, you can identify if the task is within recommended limits or not.

 

A lift analysis tool (in an Excel spreadsheet) can be downloaded from a website posted by Dr. Tom Bernard of the University of South Florida.  To use the tool, you follow these simple steps:

 

• Identify the horizontal distance of an object from the body at the origin and destination of the lift (Distance of hands from the ankle bones)
• Identify the distance of the hands from the floor at the origin and destination of the lift
• Identify the weight of the object lifted
• Identify the asymmetry of the torso (how much the shoulders are turned from the straight ahead position)
• Identify how many times the object is lifted per minute
• Identify how good the hand grip is
• Identify how much time per day is occupied with this task

 

To complete your analysis, enter your assessment results into the spreadsheet.  The macros in the tool will identify the recommended weight limit (RWL) and lifting index (LI – how much the task is above or below the RWL).  “What if?” scenarios can be evaluated for possible modifications to the task, in order to identify the best method of keeping the task at the RWL.

 

 

Machine Guards and the Cost of Cutting Corners

Henry Reynolds, who works at MEMIC as a safety management consultant, recently told me a story that is a reminder about the importance of machine guarding. And why it’s smart to resist the temptation to cut corners.
 
“I recently had an accident at a company where an employee amputated two fingers and partially amputated two others on his right hand. When I asked the employees’ manager if the accident could have been prevented, the answer was not surprising. Had the operator done the machine set up properly, then yes, this accident could have been prevented. After discussing the proper machine set up procedure, I questioned why the machine wasn’t set up properly, with the machine guard. Again, receiving an unsurprising answer:  'It wasn't feasible.'

Digging deeper, I asked why setting up the machine, with the machine guard on, was not feasible and received the answer I knew was coming. With the machine guard off, set-up was 10 minutes.  With it on, set-up was an hour. The next question was clearly asked too late: Was one hour and saving an employees’ fingers more cost-effective than a shorter set up?

Machine Guarding Standard 29 CFR 1910.211 through 243 specifies areas to be guarded on all types of equipment. It specifies that guards must be affixed to the machines 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.

Here are a few questions to ask when reviewing your machine guards.
o Are all rotating shafts guarded?
o Are employees protected from flying chips from machining?
o Are fingers and arms away from pinch and nip points?
o Are the guards adequate for the machines?
o Have your employees been educated on machine guarding and it's importance?
o Have you done a hazard analysis on each piece of equipment to determine the hazard and what the controls would be?
o After guards are in place, are you inspecting them on a regular basis?
o When a deficiency is found is it corrected immediately?

When all is said and done, we should not hear that machine guarding is not feasible. Where there is a will, there is a way. In tough economic times, you might be tempted to save a few dollars, but cutting corners isn’t going to save money in the long run. It might also be hard to challenge your employees, or your managers, to change their way of thinking about machine guarding.

 The old “Seven Steps of Stagnation” are worth reviewing when educating your employees and/or managers on the many reasons for proper machine guarding. The Seven Steps of Stagnation are:

1. We've never done it that way.  
2. We're not ready for that.
3. We're doing alright without it.  
4. We tried that once before.
5. It costs too much.
6. That's not our responsibility.
7. It just won't work.

If you need further assistance with machine guarding issues and inspections on equipment to verify proper guarding you may contact your safety management consultant. You can also check out these resources on machine guarding:

OSHA Concepts and Techniques of Machine Safeguarding

OSHA "e-Tool" Machine Guarding

Lab Safety's EZ Fact, General OSHA Machine Guarding Requirements

A great resource for aiding in machine guarding solutions is Rockford Systems, Inc. I recommend them to many of my clients in need of machine guard solutions. Another great resource for machine guard solutions is contacting the manufacturer directly. More times than not the manufacturer will offer machine guards or be able to put you in touch with the company that makes the specific guards for your machine. Feel free to let us know of your favorite machine guarding resources.”