- Record Type:OSHA Instruction
- Current Directive Number:CPL 2-1.24
- Old Directive Number:CPL 2-1.24
- Title:National Emphasis Program on Mechanical Power Presses, 29 C.F.R. 1910.217.
- Information Date:
- Standard Number:
May 6, 1997
| MEMORANDUM TO: | ALL REGIONAL ADMINISTRATORS |
| ATTENTION: | MECHANICAL POWER PRESS NEP COORDINATORS |
| FROM: | JOHN B. MILES, JR., DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS |
| SUBJECT: | Correction for OSHA Instruction CPL 2-1.24, National Emphasis Program on Mechanical Power Presses, 29 CFR 1910.217 |
The purpose of this memorandum is to provide the field with interim change pages for the recently released Directive on the National Emphasis Program for Mechanical Power Presses. Page G-16 of the Directive inadvertently included a paragraph describing an 8-hour training requirement for press operators. No such requirement exists in the standard at 1910.217, and the error has been corrected in the attached pages. Please ensure that all Area Office, State Plan and appropriate Regional personnel receive a copy of this correction notice.
We will be at some point in the future publish a formal Change 1 to
this Directive. This memorandum is meant to avoid any further
confusion and provide clarification to the regulated community.
OSHA Instruction CPL 2-1.24
February 28, 1997
Directorate of Compliance Programs
SUBJECT: National Emphasis Program on Mechanical Power Presses, 29 C.F.R. §1910.217.
A. Purpose. This directive describes policies and procedures for implementing a National Emphasis Program (NEP) to reduce and eliminate the workplace incidence of hazards associated with mechanical power presses.
B. Scope. This instruction applies OSHA-wide. The OSHA program is delivered in 40% of the nation's workplaces by the 25 states that operate OSHA approved state plans. These states are encouraged to adopt similar policies but may choose to develop and implement alternatives. See paragraph F.
C. References.
- 1. OSHA Instruction CPL 2.102, March 28, 1994, Procedures for Approval of Local
Emphasis Programs and Experimental Programs.
- 2. OSHA Standard 29 CFR §1910.217.
- 3. OSHA's Safety and Health Management Guidelines, 54 FR 3904, January 26, 1989.
- 4. OSHA Instruction CPL 2.25I, January 4, 1995, Scheduling System for Programmed
Inspections.
- 5. Executive Order 12196, Section 1-201.
- 6. OSHA Standard 29 CFR 1960.16.
- 7. OSHA Instruction STP 2.22A, CH-2, January 29, 1990, State Plan Policies and
Procedures Manual(SPM).
- 8. OSHA Instruction CPL 2.103, September 26, 1994, Field Inspection
Reference Manual (FIRM).
D. Action. The policies and procedures set forth in this directive are effective immediately. OSHA Regional Administrators, Area Directors and National Office Directors shall ensure that the policies and procedures set forth in this directive are followed.
Regional Administrators shall also ensure that the State Consultation Program Managers and the State Plan State Designees in their Regions are apprised of the contents of this NEP and its required Area Office Outreach initiatives. Regional Administrators are to encourage the Consultation Programs' involvement in this Agency-wide effort.
E. Application. This instruction applies to inspections of general industry employers whose workplaces include mechanical power presses.
F. Federal Program Change. This instruction impacts State programs. Each Regional Administrator shall:
- 1. Ensure that this change is promptly forwarded to each State designee, using a format
consistent with the Plan Change Two-Way Memorandum in Appendix P, OSHA
Instruction STP 2.22A, CH-2, SPM.
- 2. Explain the content of this change to the State designee.
- 3. Ensure that States are encouraged, but not required, to adopt an identical or alternative
policy. States shall be asked to provide preliminary notification to the Regional
Administrator within 30 days from the date of this introduction of their intent to adopt
or not to adopt the procedures in this directive. The State shall formally respond to
this change with an indication of their intent within 70 days in accordance with
paragraph I.1.a.(2)(a) and (b), Chapter III or Part I of the SPM. If the State adopts
identical procedures, no further plan change supplement need be submitted. If the
State adopts different compliance procedures, a copy of the procedures shall be
provided to the Regional Administrator within six months from the date of this
directive for review.
- 4. Review policies, procedures, and instructions issued by the State and monitor their
implementation as provided in a Performance Agreement or through routine
monitoring focussing on impact and results.
G. Background. OSHA has determined that a National Emphasis Program is needed because of the continuing incidence of injuries that have resulted from the operation of mechanical power presses. The hallmark of OSHA's enforcement policy is achieving optimal worker protection. Under The New OSHA, National Performance Review, May 1995, enforcement policies consider both an employer's efforts at adopting protective measures and its efforts toward the abatement of hazards.
The operation of a mechanical power press can be extremely dangerous and compliance with OSHA's mechanical power press standard is frequently overlooked. Injuries involving mechanical power presses often result in death or permanent disability and OSHA's inspection history indicates that employee exposures to these hazards are prevalent in many workplaces. Section 1910.217 provides for safety measures that need to be undertaken regarding the safe operation of mechanical power presses. This NEP provides additional information on how to identify and guard against these hazards.
H. Program Procedures. This NEP includes three major field activities: outreach, targeting/selection, and inspection. The outreach phase of the Program is to begin 30 days from the effective date of this directive. Inspections are to begin 90 days after the outreach period is initiated.
- 1. Outreach. Each Regional and Area Office shall concurrently develop outreach
programs that support the purpose of this NEP, to reduce and eliminate workplace
hazards associated with mechanical power presses. Programs may include letters to
employers, professional associations, and local unions or other activities designed to
involve labor and management stakeholders in the elimination of power press
hazards. The Office of Information and Consumer Affairs will provide support to the
Regional and Area Offices.
- At the discretion of the Regional and Area Offices, outreach materials may either be
mailed directly or made available upon request to employers, professional
associations, and local unions. The attached appendices provide useful information
which may be used, in whole or in part, by the Regional and Area Offices.
- 2. Site Selection. Inspections conducted under this NEP shall be scheduled and
conducted pursuant to the following priorities. Inspections shall concentrate on
particular establishments where work-related injuries are likely or where there have
been known injuries involving mechanical power presses. The following is a list of
sources for obtaining information to develop a roster from which inspections will be
conducted.
- a. Standard Industrial Classification (SIC) Codes. The table below represents
national data on the ten SICs with the highest number of 29 CFR §1910.217
violations for the period September, 1990 through February,1996. Each Area
Office shall either use these SICs, or prepare its own list of establishments for
the top ten (10) SIC codes in the Area Office's jurisdiction, based on IMIS data
from the previous three years. Establishments with fewer than ten employees
are to be included in this Program. Consult the current appropriation riders for
exempt employers in any given SIC (see the current version of OSHA
Instruction CPL 2.51 for exempt SICs for any given fiscal year).
| Rank | All federal states (10/1/90-2/23/96) |
| 1. | 3469(204) stamping |
| 2. | 3444(135) sheet metal |
| 3. | 3442(92) metal doors |
| 4. | 3441(68) fab. steel |
| 5. | 3429(60) hardware |
| 6. | 2542(60) manuf. furniture |
| 7. | 3714(56) motor vehicles |
| 8. | 3499(48) misc. metal |
| 9. | 3443(44) boiler shops |
| 10. | 3496(39) wire |
- b. Additions to list based on local data. Area Offices shall attempt to obtain and
use additional data to further identify and add establishments where serious
injuries or fatalities related to power presses have occurred in the last three
years. Local information could include, where available, workers'
compensation data, OSHA 200 data, and hospital discharge data. The basis for
addition of an establishment shall be documented.
- c. Each establishment on the list shall be given a sequential number.
Establishments that are added based on paragraph (b) above may be added to the
bottom of the list or inserted elsewhere in the list within a similar SIC category.
Administratively neutral criteria shall be applied when selecting from the list of
establishments developed from the SIC Codes and local data. The random
numbers table (see OSHA Instruction CPL 2.25I) shall be used to identify
individual establishments to be inspected. Area Offices may delete facilities that
are not likely to have hazards associated with mechanical power presses or firms
which are known to be out of business, documenting the basis for such
determination. Further, in accordance with the FIRM, any establishment having
had a safety inspection in the last three years shall be deleted from the list.
- d. Program approval. Each Area Office's inspection program must be approved by
the Regional Administrator and the Regional Solicitor. This is most easily
accomplished by setting out the targeting and selection system in a Regional
Program Directive, as for a Local Emphasis Program. Other forms of
documentation may, however, be used at the discretion of the Regional
Administrator.
- 3. Inspection Procedures. Inspections initiated under this NEP shall be scheduled and
conducted in accordance with provisions of the FIRM, except as noted below.
- a. Inspections will be limited to hazards associated with mechanical power presses,
but the CSHO may expand the scope of the inspection beyond mechanical
power presses if other hazards or violations are observed. Inspections shall be
scheduled beginning the current fiscal year, and will continue until further
notice.
- b. Because the nature of this program may yield a number of significant cases,
Area Directors, Supervisors, and CSHOs should ensure that the requirements for
case development are being met.
I. Scheduling and Resource Allocation.
- 1. This is a National initiative, which affects existing inspection scheduling priorities, as
indicated below. Area Offices shall develop and implement targeting systems which
are suited to the Region's resources and the needs of workers in their jurisdictions.
- a. Resources. Regional Administrators shall ensure that adequate resources are
designated for this NEP.
- b. Planning. Each Regional Administrator shall report, to the Director of
Compliance Programs, the number of NEP inspections that are planned for each
quarter of the fiscal year, and shall report, 30 days after the end of each quarter,
the number of such inspections actually conducted.
- c. Priority. Inspections conducted under this NEP have a lower priority than
inspections conducted under Cooperative Consultation Programs (CCP), but
have a higher priority than other programmed inspections. Where possible,
mechanical power presses can be inspected during CCP inspections.
- d. Conflicts. Other National, Regional or local Programs, including redesigned
Area Office activities/problem solving initiatives, may compete with this NEP
for available staff resources. Nonetheless, conflicts must be resolved to ensure
that the NEP is implemented in each Area Office. Thus, this NEP may be
combined with other initiatives which identify targets on a different basis. For
example, a Local Emphasis Program (LEP) which targets specific industries,
rather than hazards, may be combined with this NEP by addressing the relevant
hazards as part of a combination NEP/LEP inspection.
J. Coordination.
- 1. National Office. This NEP will be coordinated in the Office of Safety Compliance
Assistance, Directorate of Compliance Programs. Questions and comments should be
directed to the National Coordinator in that Office.
- 2. Field. Each Regional Administrator shall name a coordinator for this National
Emphasis Program.
K. Consultation Programs. The National Office has involved the State Consultation Program with the development of this NEP. Activities are underway to incorporate state consultative services concurrently into the outreach/enforcement approach of this program. Special efforts will be made at the National Office level to ensure that consultation staff is offered training courses and outreach materials. Similarly, Area Offices within the same state jurisdiction are strongly encouraged to include their state 7(c)(1) program contacts in the development and implementation of their local program. The State Consultation Program will also be encouraged to develop their own strategic approaches to address the need to reduce injuries and accidents related to power presses.
L. Training. Because of the technical nature of mechanical power presses, CSHOs who conduct inspections under this NEP and consultation staff must have had adequate training or experience with mechanical power presses.
- 1. The OSHA Training Institute (OTI). The OTI provides training materials to CSHOs,
consultation staff, and, employers. Also, additional sessions of the OTI's mechanical
power press course can be made available. Technical training at the OTI can be
expanded to include the use of a time-stop measuring device to measure the safety
distance on a power press, should it be determined that such training is needed.
- 2. Additional Training.
- a. On-the-Job Training. Area Directors and supervisors shall ensure that
inexperienced CSHOs also receive on-the-job training by accompanying
experienced compliance officers during power press inspections.
- b. Enforcement and Compliance Issues. Continuing guidance regarding
enforcement and compliance issues will be provided as new issues arise.
M. Federal Agencies. This instruction describes a change that affects Federal agencies. Executive Order 12196, Section 1-201, and 29 CFR §1960.16, maintains that Federal agencies must also follow the enforcement policy and procedures contained in this Directive.
N. Program Evaluation. Area Offices shall collect data relevant to the effectiveness of this NEP and submit it to the Regional Office. The Regional Office, after summarizing the information, will forward it to the National Office at the end of the year. At a minimum the evaluation should respond to the requirements of CPL 2.102 G.4. Evaluations.
O. IMIS Coding.
- 1. Current instruction for completing enforcement forms OSHA-1,
OSHA-7, OSHA-36, and OSHA-90 and Consultation Request Form-20 and Visit
Form-30 shall be applied when recording inspections conducted under this NEP as
follows:
- a. The OSHA-1 Form for any programmed inspection covered under this national
emphasis program for mechanical power presses in all industries shall be
marked "PLANNED" (Item 24h) and "NATIONAL EMPHASIS PROGRAM"
(Item 25d). Record PWRPRESS in the space in item 25d.
- b. The OSHA-1 Form for any unprogrammed inspection shall be marked as
unprogrammed (Item 24a through gas appropriate). In addition, it shall be
marked "NATIONAL EMPHASIS PROGRAM" (Item 25d). Record
PWRPRESS in the space item 25d.
- c. Whenever an OSHA-7 is completed by a Federal office and the applicable
complaint alleges the presence of power
press-related hazards, complete the OSHA-7 in the usual manner, but include
the code for power presses in "Optional Information" Item No. 46. The
following format should be used:
| TYPE | ID | VALUE |
| N | 16 | PWRPRESS |
- d. Whenever an OSHA-36 is completed by a Federal office and the inspecting
CSHO is able to identify at the site of the fatality / catastrophe the existence of
power press-related hazards, complete the OSHA-36 in the usual manner, but
include the code for Power presses in "Optional Information" Item No. 35. The
following format should be used:
| TYPE | ID | VALUE |
| N | 16 | PWRPRESS |
- e. Complete the OSHA-90 in the usual manner and enter the code for power
presses in "Optional Information" Item No. 26, when an OSHA-90 is completed
by a Federal office and the applicable referral case has power presses as one of
the subjects of the file. The following format should be used:
| TYPE | ID | VALUE |
| N | 16 | PWRPRESS |
- 2. Consultation.
- a. Whenever a visit is made in response to this NEP, a Consultation Request Form
and / or Visit Form is to be completed as follows:
- (1) Complete the Consultation Request Form-20 in the usual manner and enter
the code for power press in "Optional Information" Item No. 26, when a
visit has been made in response to the NEP. The following information
should be used:
| TYPE | ID | VALUE |
| N | 16 | PWRPRESS |
- (2) Complete the Visit Form-30 in the usual manner and enter the code for
power presses in "Optional Information" Item No. 34, when a visit has
been made in response to the NEP. The following in formation should be
used:
| TYPE | ID | VALUE |
| N | 16 | PWRPRESS |
P. Appendices. The Appendices contain a variety of information developed to assist employers, employees, and compliance officers in the implementation, training and outreach requirements of this Program. The Area Office may use its discretion in selecting whatever materials deemed appropriate and feasible for outreach purposes.
Appendix A: Useful Formulas: Safety Distances and Table 0-10
Appendix B: Full Revolution Clutch Presses support materials
- -- Summary of applicable 217 provisions
- -- Safety distance formula and graph
- -- A partial list of engagement points
- -- Weekly inspection report -- sample
- -- Monthly inspection report -- sample
Appendix C: Part Revolution Clutch Presses support materials
- -- Summary of applicable Section 1910.217 provisions
- -- Safety distance formula and graph
- -- Weekly inspection report -- sample
- -- Periodic inspection report -- sample
Appendix D: Sample pullout/restraint inspection checklist
Appendix E: Safeguards and other hazards
Appendix F: Point of Operation injury sample report
Appendix G: Mechanical Power Presses -- Questions and Answers
Greg Watchman
Acting Assistant Secretary
DISTRIBUTION:
National, Regional, and Area Offices
All Compliance Officers
State Designees
NIOSH Regional Program Directors
7(c)(1) Project Manager
Appendix A: Press Safety Distances
A. Use of Table. It shall be the responsibility of the employer to provide and insure the usage of
Point of Operation guards or properly applied and adjusted Point of Operation devices on every
operation performed on a mechanical power press except when the Point of Operation opening is
one-fourth inch or less. When the opening exceeds one-fourth inch, then Table A.1 must be
followed.
| Distance of Opening from Point of Operation Hazard (inches) |
Maximum width of opening (inches) |
|
1/2 to 1-1/2 1-1/2 to 2-1/2 2-1/2 to 3-1/2 3-1/2 to 5-1/2 5-1/2 to 6-1/2 6-1/2 to 7-1/2 7-1/2 to 12-1/2 12-1/2 to 15-1/2 15-1/2 to 17-1/2 17-1/2 to 31-1/2 |
1/4 3/8 1/2 5/8 3/4 7/8 1-1/4 1-1/2 1-7/8 2-1/8 |
B. Safe Distance, Part Revolution Press. Stopping time is measured in hundredths of a second, multiplied by 63 inches. The easiest way to calculate safe distance is to move the decimal over like this. If stopping time was measured at ½ second or 500 milliseconds, the minimum safe distance is ½ of 63 inches or approximately 2 ½ feet from the forward most Point of Operation. Remember 63 inches is approximately 5 feet. If stopping time was measured to be 100 milliseconds, then the minimum safe distance would be 6.3 inches. Always determine from examining all dies used in a particular press what the forward most Point of Operation is and then measure forward of it to locate your safety device. It's always a good idea once safe distance is calculated to note this right at the press with the following information:
- 1. Date of measurement
- 2. Stopping Time
- 3. Safe Distance Calculation
- 4. Added distance to allow for normal deterioration so that position of your safeguard
does not have to be relocated after a short period of time.
- 5. Your forward most Point of Operation die location.
- 6. Your fixed location of your safety device or safe guard.
C. Safe Distance, Full Revolution Press. Safe distance on full revolution presses is directly
related to continuous press speed and the number of engagement points in the clutch. The two
hand trips become impractical as a primary safe guard, since in most cases, they would have to be
relocated at such a distance from the Point of Operation that production would be reduced below
an acceptable level. If the press had a multiple pin engagement clutch (14 points or more) and
the press operated at a continuous speed of over 15 inches from the Point of Operation, then the
two hand trip is practical. If the press has fewer engagement points or is slower, the
consideration of another safe guard would be most practical.
A. Summary of Applicable Provisions of Section 1910.217 for Full Revolution Positive Clutch Presses.
- 1. Safeguarding:
- a. Guards: Prevent entry of hands - (c)(2)(I)(a)
- Conform to Table A-1 - (c)(2)(I)(b)
- Use fasteners - (c)(2)(I)(c)
- b. Pull-outs: (c)(3)(iv)(a, b, c, d)
- c. Two Hand Trips: Protected, Both Hands, Concurrent Pressure - (b)(6)(I)
- Anti-repeat - (b)(6)(ii)
- Safe distance - (c)(3)(viii)(c).
- You must:
- (1) Obtain time for one revolution
- (2) Obtain the number of engaging points
- (3) Use Table A-1 to obtain safe distance
- 2. Inspections:
- Weekly - (e)(1)(ii)
- Periodic - (e)(1)(I)
- Pull-outs - (c)(3)(iv)(d), only when used as the primary safeguard
- 3. Training:
- Operator - (f)(2)
- Maintenance - (e)(3)
- 4. Motor Controls:
- Disconnect - (b)(8)(I)
- Buttons - (b)(8)(ii)
- Magnetic - (b)(8)(iii)
- 5. Single-stroke mechanism: (b)(3)(I), (ii)
B. Comparison Graph of minimum safety distances.
C. Partial List of Engagement Points - Full Revolution Presses.
| # OF ENGAGEMENT POINTS | PRESS MFG |
| 14 | NIAGARA ONLY |
| 4 | * BLISS * MINISTER * PRESS RITE |
| 3 | ALVA ALLEN JOHNSON VERSON * BLISS CLEARING CLEVELAND CONSOLIDATED DANLY DIAMONT FEDERAL MINISTER FERRACUTE L & J TOLEDO * PERKINS ROBINSON * ROBINSON ROCKFORD ROUSELLE V & O WALSH WILLIAM/WHITE |
| 2 | ALVA ALLEN KENCO * BENCHMASTER * PERKINS * GILRO * PRESSRITE |
| 1 | * BENCHMASTER FAMCO * GILRO |
| * NOTES SOME OVERLAP |
D. SAMPLE FORM - Mechanical Power Press Weekly Inspection Record for Full
Revolution Power
(The purpose of this form is to provide compliance assistance information to interested
parties required to comply with Subpart O, 1910.217(e) regulations for mechanical power
presses. This non-mandatory format has been developed to list components of machines
common to most power presses, although it is not an exhaustive listing. The employer is
responsible for consulting the manufacturer's recommendations on each power press in
operation and fully complying with the letter and intent of 1910.217(e).
MACHINE NO._________________________ DEPARTMENT_________________________
DATE_____________________
NOT DATE OF
OK OK PART INSPECTED IF NOT OK, CONDITIONS CORRECTION
____ ____ Floor Condition
Clean _____________________________________ ____________
____ ____ Lighting at Press _________________________ ____________
____ ____ Operator Properly
Trained ___________________________________ ____________
____ ____ Lower & Upper
Treadle ___________________________________ ____________
____ ____ Brake-Collar ______________________________ ____________
____ ____ Collar Key Strap,
Fixed Half,Hinged Half,
Hinge Pin, Adjustment Spring,
Band Nut Adjustment
Stud ______________________________________ ____________
____ ____ Latch Bracket,
Latch Spring ______________________________ ____________
____ ____ Anti-Repeat _______________________________ ____________
____ ____ Single Stroke
Mechanism _________________________________ ____________
____ ____ Air Gauge
(condition-accuracy) ______________________ ____________
____ ____ Air Cylinder/Valves _______________________ ____________
____ ____ Push-Palm Buttons
& Wiring __________________________________ ____________
____ ____ Two Hand Trips at
Safe Distance _____________________________ ____________
____ ____ Safeguard Adjusted to
Table 0-10 ________________________________ ____________
____ ____ Relays, Switches, etc. ____________________ ____________
COMMENTS:______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
INSPECTED BY:__________________________________________________________
_______________________________________________________________________
(Name and Job Title)
PRESS APPROVED FOR OPERATION _______________________________________
RED TAGGED
E. SAMPLE FORM - Mechanical Power Press Periodic Inspection Record for Full Revolution Power Presses.
(The purpose of this form is to provide compliance assistance information to interested
parties required to comply with Subpart O, 1910.217(e) regulations for mechanical power
presses. This non-mandatory format has been developed to list components of machines
common to most power presses, although it is not an exhaustive listing. The employer is
responsible for consulting the manufacturers recommendations on each power press in
operation and fully complying with the letter and intent of 1910.217(e).
MACHINE NO._________________________ DEPARTMENT_________________________
DATE_____________________
NOT DATE OF
OK OK PART INSPECTED IF NOT OK, CONDITIONS CORRECTION
____ ____ Floor Condition Clean _____________________ ____________
____ ____ Piping to Press
(air power) _______________________________ ____________
____ ____ Lighting at Press _________________________ ____________
____ ____ Operator Properly
Trained ___________________________________ ____________
____ ____ Bolster Plate
Secure ____________________________________ ____________
____ ____ Inclining Screw,
Ratchet,Screw Pin,
Cotters for
Screw Pin _________________________________ ____________
____ ____ Lower & Upper
Treadle ___________________________________ ____________
____ ____ Tie Rods __________________________________ ____________
____ ____ Leg Clamp &
Pivot Bolt ________________________________ ____________
____ ____ Brake-Collar ______________________________ ____________
____ ____ Collar Key Strap, Fixed
Half, Hinged Half, Hinge
Pin, Adjustment Spring,
Band Nut Adjustment Stud __________________ ____________
____ ____ Latch Bracket,
Latch Spring ______________________________ ____________
____ ____ Flywheel End
Collar Pin ________________________________ ____________
____ ____ Anti-Repeat _______________________________ ____________
____ ____ Single Stroke Mechanism ___________________ ____________
____ ____ All Parts & Screws Secure _________________ ____________
____ ____ Frame & Base for Cracks ___________________ ____________
____ ____ Bearing Clearances ________________________ ____________
____ ____ Slide-Jib Clearance _______________________ ____________
____ ____ Main-Drive (belts, gears) _________________ ____________
____ ____ Air Gauge
(condition-accuracy) ______________________ ____________
____ ____ Air Cylinder/Valves _______________________ ____________
____ ____ Push-Palm Buttons
& Wiring __________________________________ ____________
____ ____ Ground Fault Potential ____________________ ____________
____ ____ Lubrication System ________________________ ____________
____ ____ Two-Hand Trips at Safe
Distance __________________________________ ____________
____ ____ Safeguard Adjusted to
Table 0-10 ________________________________ ____________
____ ____ Safeguard Interlocks ______________________ ____________
____ ____ Motor Controls ____________________________ ____________
____ ____ Relays, Switches, etc. ____________________ ____________
COMMENTS:______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
INSPECTED BY:__________________________________________________________
_______________________________________________________________________
(Name and Job Title)
PRESS APPROVED FOR OPERATION _______________________________________
RED TAGGED
Appendix C: Support Materials - Part Revolution Clutch Presses
A. Summary of Applicable Provisions of Section 1910.217 for Part Revolution Positive Clutch Presses.
Summary of Applicable Provisions of Section 1910.217 for Part Revolution Positive Clutch
Presses (continued).
B. Comparison Graph of minimum safety distances.
C. SAMPLE FORM - Mechanical Power Press Weekly Inspection Record for Partial Revolution Power Presses.
(The purpose of this form is to provide compliance assistance information to interested parties required to comply with Subpart O, 1910.217(e) regulations for mechanical power presses. This non-mandatory format has been developed to list components of machines common to most power presses, although it is not an exhaustive listing. The employer is responsible for consulting the manufacturers recommendations on each power press in operation and fully complying with the letter and intent of 1910.217(e).
MACHINE NO._________________________ DEPARTMENT_________________________
DATE_____________________
NOT DATE OF
OK OK PART INSPECTED IF NOT OK, CONDITIONS CORRECTION
____ ____ Floor Condition Clean _____________________ ____________
____ ____ Lighting at Press _________________________ ____________
____ ____ Operator Properly Trained _________________ ____________
____ ____ Brake-Collar ______________________________ ____________
____ ____ Collar Key Strap, Fixed
Half, Air Cylinder Operating,
Hinged Half, Hinge Pin,
Adjustment Spring, Band
Nut Adjustment ____________________________ ____________
____ ____ Push-Palm Buttons & Wiring ________________ ____________
____ ____ Ground Fault Potential ____________________ ____________
____ ____ Rotary Limit Switch Secure
& Cams, Relays Secure &
Adjusted __________________________________ ____________
____ ____ Main Control Cabinet Secure
& Closed After Inspection for
Oil, Grease, etc., and Proper
Functioning of all Components,
Devices Contained
Therein ___________________________________ ____________
____ ____ Main Motor Controls
Operating _________________________________ ____________
____ ____ Slide Adjust Motor Controls _______________ ____________
____ ____ Designated Wiring Secure
at Proper Terminal Points _________________ ____________
____ ____ Foot Switch, Spring
& Wiring __________________________________ ____________
____ ____ Main Clutch Valves
Operating _________________________________ ____________
____ ____ Brake Operating, Clean &
Adjusted __________________________________ ____________
____ ____ Stopping Time at 90o
Milliseconds ______________________________ ____________
____ ____ Safe Distance of
Safeguard OK ______________________________ ____________
____ ____ Anti-repeat _______________________________ ____________
____ ____ Barrier Guard Adjusted to
Table 0-10 ________________________________ ____________
COMMENTS:______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
INSPECTED BY:__________________________________________________________
_______________________________________________________________________
(Name and Job Title)
PRESS APPROVED FOR OPERATION _______________________________________
RED TAGGED _____________________
C. SAMPLE FORM - Mechanical Power Press Periodic Inspection Record for Partial Revolution Power Presses.
(The purpose of this form is to provide compliance assistance information to interested parties required to comply with Subpart O, 1910.217(e) regulations for mechanical power presses. This non-mandatory format has been developed to list components of machines common to most power presses, although it is not an exhaustive listing. The employer is responsible for consulting the manufacturers recommendations on each power press in operation and fully complying with the letter and intent of 1910.217(e).
MACHINE NO._________________________ DEPARTMENT_________________________
DATE_____________________
NOT DATE OF
OK OK PART INSPECTED IF NOT OK, CONDITIONS CORRECTION
____ ____ Floor Condition Clean _____________________ ____________
____ ____ Piping to Press (air,
power) ____________________________________ ____________
____ ____ Lighting at Press _________________________ ____________
____ ____ Operator Properly
Trained ___________________________________ ____________
____ ____ Bolster Plate Secure ______________________ ____________
____ ____ Inclining Screw, Ratchet,
Screw Pin, Cotters for Screw
Pin _______________________________________ ____________
____ ____ Tie Rods __________________________________ ____________
____ ____ Leg Clamp &
Pivot Bolt ________________________________ ____________
____ ____ Brake-Collar ______________________________ ____________
____ ____ Collar Key Strap, Fixed Half,
Air Cylinder Operating, Hinged
Half, Hinge Pin, Adjustment
Spring, Band Nut
Adjustment ________________________________ ____________
____ ____ Fly Wheel End Collar Pin __________________ ____________
____ ____ All Parts & Screws Secure _________________ ____________
____ ____ Frame & Base for cracks ___________________ ____________
____ ____ Bearing Clearances ________________________ ____________
____ ____ Slide-Jib Clearances ______________________ ____________
____ ____ Main-Drive (belts, gears) _________________ ____________
____ ____ Air Gauge
(condition-accuracy) ______________________ ____________
____ ____ Push-Palm Buttons
& Wiring __________________________________ ____________
____ ____ Ground Fault Potential ____________________ ____________
____ ____ Rotary Limit Switch Secure
& Cams, Relays Secure &
Adjusted ___________
____ ____ Operator's Station Secure _________________ ____________
____ ____ Main Control Cabinet Secure
& Closed After Inspection for
Oil, Grease, etc., and Proper
Functioning of all Components,
Devices Contained
Therein ___________________________________ ____________
____ ____ Main Motor Controls
Operating _________________________________ ____________
____ ____ Slide Adjust Motor
Controls __________________________________ ____________
____ ____ Designated Wiring Secure at
Proper Terminal Points ____________________ ____________
____ ____ Foot Switch, Spring &
Wiring ____________________________________ ____________
____ ____ Lubrication Operating at all
Designated Points _________________________ ____________
____ ____ Main Clutch Valves
Operating _________________________________ ____________
____ ____ Brake Operating, Clean,
Adjusted __________________________________ ____________
____ ____ Stopping Time at 90o
Milliseconds ______________________________ ____________
____ ____ Safe Distance of Safeguard OK _____________ ____________
____ ____ Anti-Repeat _______________________________ ____________
____ ____ Barrier Guard Adjusted to
Table 0-10 ________________________________ ____________
COMMENTS:______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
INSPECTED BY:__________________________________________________________
_______________________________________________________________________
(Name and Job Title)
PRESS APPROVED FOR OPERATION ______________________________________
RED TAGGED _____________________
Appendix D: Sample Pullout/Restraint Inspection Checklist
Each pull-out device or restraint in use shall be visually inspected and checked for proper
adjustment at the start of each operator shift, following a new die set-up, and when operators are
changed. Necessary maintenance, repair, or both shall be performed and completed before the
press is operated.
MACHINE NO. ________________________ DEPARTMENT ______________________
OPERATOR I.D._______________________
DATE _______________ TIME ________________ SHIFT CHANGE _____________
DIE CHANGE ______________________ OPERATOR CHANGE ____________________
A SEPARATE DEVICE SHALL BE PROVIDED FOR EACH OPERATOR IF MORE THAN
ONE OPERATOR IS USED ON A PRESS. PART INSPECTED APPLIED TO EACH DEVICE.
NOT DATE OF
OK OK PART INSPECTED IF NOT OK, CONDITIONS CORRECTION
____ ____ All parts, nuts,
bolts,etc. secure _________________________ ____________
____ ____ Attachments connected
to and being operated
only by the press slide
or upper die ______________________________ ____________
____ ____ Attachments adjusted to
prevent each operator
from reaching into the point
of operation or to withdraw
the operator's hands from the
point of operation before the
die closes ________________________________ ____________
____ ____ Horizontal support
Secure ____________________________________ ____________
____ ____ Vertical support
secure ____________________________________ ____________
____ ____ Cables must not be
bent,frayed or twisted ____________________ ____________
____ ____ Brackets secure and in good
condition _________________________________ ____________
____ ____ Visual inspection
of total system ___________________________ ____________
I, the undersigned, certify that on this date and time, I followed the
above inspection procedure on the indicated machine and found the
device/devices in good operating condition and properly adjusted to
ensure the safe operation of the press by the operator/operators.
Signature _____________________________________________________________
(Name and Job Title)
PULL-OUTS APPROVED FOR OPERATION ______________________________________
RED TAGGED _____________________
safeguards and other hazards
Answers to the following questions should help the interested reader to determine the safeguarding needs of his or her own workplace, by drawing attention to hazardous conditions or practices requiring corrections.
1. Do the safeguards provided meet the minimum OSHA requirements?
2. Do the safeguards prevent workers' hands, arms, and other body parts from making contact with dangerous moving parts?
3. Are the safeguards firmly secured and not easily removable?
4. Do the safeguards ensure that no objects will fall into the moving parts?
5. Do the safeguards permit safe, comfortable, and relatively easy operation of the machine?
6. Can the machine be oiled without removing the safeguard?
7. Is there a system for shutting down the machinery before safeguards are removed?
8. Can the existing safeguards be improved?
The Point of operation:
1. Is there a point-of-operation safeguard provided for the machine?
2. Does it keep the operator's hands, fingers, body out of the danger area?
3. Is there evidence that the safeguards have been tampered with or removed?
4. Could you suggest a more practical, effective safeguard
5. Could changes be made on the machine to eliminate the point-of operation hazard entirely?
Power transmission apparatus:
1. Are there any unguarded gears, sprockets, pulleys, or flywheels on the apparatus?
2. Are there any exposed belts or chain drives?
3. Are there any exposed set screws, key ways, collars, etc.?
4. Are starting and stopping controls within easy reach of the operator?
5. If there is more than one operator, are separate controls provided?
Other moving parts:
1. Are safeguards provided for all hazardous moving parts of the machine, including auxiliary parts?
1. Have appropriate measures been taken to safeguard workers against noise hazards?
2. Have special guards, enclosures, or personal protective equipment been provided, where necessary, to protect workers from exposure to harmful substances used in machine operation?
1. Is the machine installed in accordance with National Fire Protection Association and National Electrical Code requirements?
2. Are there loose conduit fittings?
3. Is the machine properly grounded?
4. Is the power supply correctly fused and protected?
5. Do workers occasionally receive minor shocks while operating any of the machines?
POINT OF OPERATION INJURY REPORT (1910.217(g))
EMPLOYER
Name __________________________________________________________________
_______________________________________________________________________
Address________________________________________________________________
______________ Zip_____________________________________________________
Injured Employee
Name___________________________________________________________________
Description of Injury__________________________________________________
_______________________________________________________________________
Date of Injury_________________________________________________________
_______________________________________________________________________
Task Being Performed___________________________________________________
_______________________________________________________________________
(Operation, Set-Up, Maintenance or Others-Be Specific)
PRESS DESCRIPTION
Type of Press Clutch___________________________________________________
_______________________________________________________________________
(Full Revolution, Part Revolution or Direct Drive)
Type of Safeguards Being Used__________________________________________
_______________________________________________________________________
(2-Hand Control, 2-Hand Trip, Fixed Barrier Guard, Adjustable Barrier
Guard, Type "A" Gate or Movable Barrier Guard, Type "B" Gate or Movable
Barrier Guard, Presence Sensing Device, "Radio or Light Wave", Pull
Outs, Restraints, Hold Outs, etc.)
ACCIDENT CAUSE
Cause of Accident______________________________________________________
_______________________________________________________________________
(Repeat of Press, Safeguard Failure, Removing Stock Part of Scrap, No
Safeguard Provided, Safeguard Provided but not Being Used, Incorrect
Control Mode Used or Other, Improper Usage or Adjustment-Be Specific)
MACHINE LOADING
Type of Feeding________________________________________________________
_______________________________________________________________________
(Manual With Hands in Die or With Hands Out of Dies, With Hand Tools,
Semi-Automatic or Others-Be Specified)
PRESS ACTUATION
Means Used to Actuate Press Stroke_____________________________________
_______________________________________________________________________
(Foot Trip, Foot Control, Hand Trip, Hand Control or Other-Be Specific)
OPERATORS
Number of Personnel Required for Operation_____________________________
Number of Operators Provided with Controls and Safeguards______________
DATE OF REPORT_________________________________________________________
PREPARED BY____________________________________________________________
OFFICIAL POSITION______________________________________________________
_______________________________________________________________________
QUESTIONS AND ANSWERS
| Page | ||
| I. | Scope of the Standard | 2 |
| II. | Control Systems & Brake Monitor | 3 |
| III. | Presence Sensing | 4 |
| IV. | Pull-outs and Sweeps | 5 |
| V. | Two Hand Trips & Controls | 6 |
| VI. | Type A & B Gates | 8 |
| VII. | Barrier Guards & Other Safeguarding | 9 |
| VIII. | Safety Distance | 12 |
| IX. | Record Keeping | 14 |
| X. | Minimum training requirements for power press operators | 15 |
| XI. | Minimum training requirements for power pressroom supervisors | 16 |
NOTE:
Under no circumstances shall the following be used in lieu of the specific language of the law, and final determination of the requirements shall be checked with OSHA. Several questions and answers are referenced according to specific sections of the law in an attempt to provide compliance assistance to interested parties.
(I) SCOPE OF THE STANDARD
1. Q. Does the standard for mechanical power presses cover these presses when other materials are being worked such as nonferrous metals, plastic materials, or other materials?
A. The Section 1910.217 requirements do not contain a statement of scope and application at present. The intent of OSHA is to honor the scope as stated in ANSI B11.1-1971 which was adopted under Section 6 (a) of the Act. B11.1-1971 scope statement covers presses used to cut, form, ... "other materials" when the die is attached to the slide. B11.1 also covers the use of unitized tooling. The use of the mechanical power press to work on aluminum, tile, or non-ferrous metals hardly changes the need for operator safeguarding based on the material being processed.
2. Q. Are press brakes covered by the standard for mechanical power presses?
A. No.
3. Q. If a press brake is fitted with dies and functions as a mechanical power press, is safeguarding required?
A. Yes.
4. Q. What type of presses or other metal working machines are exempt from Section 1910.217?
A. Some types of presses not covered by 1910.217 are envelope making (window cutters, etc.) machines, dinkers and clickers used for cutting leather and other materials, brick presses, broaching machines, abrasive wheel presses, platen presses, powdered metal presses, hot bending and forming machines, forging presses.
5. Q. Are hot bending operations covered by Section 1910.217(a)(5)?
A. No.
(II) CONTROL SYSTEM & BRAKE MONITOR
6. Q. For ungrounded circuits, is the first ground considered a failure?
A. No.
7. Q. When operating on continuous run, is a single failure in the press control system required to stop the press?
A. No, it prevents a successive continuous run being initiated.
8. Q. If a press is only operated on continuous, must a single stroke mechanism be provided?
- 1910.217(b)(3)
- 1910.217(b)(7)(xi)
A. No.
9. Q. If a press stroke cannot be initiated because of the brake monitor action, how is this indicated to the operator?
A. The control system may have an indicator light or alarm. The visual inspection of markings on the crankshaft will show that press slide has not stopped within the safe range previously established. The press won't run.
10. Q. If the brake monitor is actuated by top stop overrun, can the brake initiation point be set earlier in the cycle if the safety distance is recalculated and two-hand controls moved?
A. Yes, this practice is allowed as long as the brake is deemed to be functioning within its stopping time limit before overhaul and repairs are required.
11. Q. If a press stops at some point of the cycle due to the brake monitor, how is the press slide returned to top of stroke?
A. The inch controls or other bypass circuit are used to return press slide to top of stroke.
12. Q. Must brake monitors detect brake deterioration when the brake is applied at other than top of stroke?
A. No, but some types of brake monitor will give an indication of stopping time on each brake application at any point in the stroke.
13. Q. Can a press be operated on-the-hop with a brake monitor?
A. No, the press slide must stop on each stroke for the brake monitor to be effective.
14. Q. Is a brake monitor necessary on a full revolution clutch press?
A. A brake monitor is not required on a full revolution clutch press. Brake monitor manufactures and users are claiming that they are feasible and useful on a full revolution clutch press.
(III) PRESENCE SENSING
15. Q. Do presence sensing devices require some form of additional guarding to protect press operators?
A. Yes, unless the sensing field covers all paths of access to the point of operations; therefore, some additional safeguarding is required such as fixed barrier guard, Type A or B gate or movable barrier device, or another presence sensing device.
16. Q. What are the limits of muting of a presence sensing device to enable parts ejection, feeding, or circuit checking?
A. Top of stroke is the point at which muting shall cease as it is not possible to set a point on the downstroke at the exact position where the hazard of die closing starts.
IV. PULL-OUTS & SWEEPS
17. Q. Are pull-outs acceptable for safeguarding the press operator when press stroke is actuated by a foot pedal or a two-hand trip not meeting the required safety distance?
A. Yes, the pull-outs by themselves are recognized as an acceptable safeguard.
18. Q. Why are detailed requirements given for checking and adjusting of pull-outs?
- 1910.217(c)(3)(iv)(d)
A. Pull-outs are a more personal form of safeguard whose proper functioning can be affected when operators are changed, or a new die set for operation. Visual inspection of pull-outs can detect wear of parts as well as proper action when press is stroking.
19. Q. Can a restraint be used for "hands in dies" feeding?
A. No. By definition the restraint does not permit entry of the hand into the die or point of operation.
20. Q. Can a restraint used for one hand be used in conjunction with a single trip or control button for the second hand, where the second hand is used for feeding into the point of operation?
A. Yes, if a safety distance is established for the one-hand trip or control button.
21. Q. What is the difference between a restraint and a pull-out device?
A. The restraint prevents entry of hands or fingers to the point of operation at all times, while the pull-out device will allow hands in dies for feeding.
22. Q. Are restraints or hold-outs a recognized form of safeguarding from the hazard of the point of operation?
A. Yes, the restraints which keep operators' hands out of the point of operation at all times are an acceptable safeguard.
23. Q. Are two-hand trips recognized as an acceptable means of safeguarding the operator from the hazard of the point of operation?
A. Yes, providing the safety distance between the point of operation and the two-hand trips is determined by the appropriate formula.
V.TWO HAND TRIPS & CONTROLS
24. Q. What are some of the methods or means used to fix the position of two-hand trips or controls at the safety distance?
A. Articulating or extendable bars or control mounts, clearly established floor position for portable control stands, or other administrative controls may be used when it is not possible to mechanically or electrically fix the portable stand or station in position.
25. Q. Can a two-hand trip be used as a safeguard on a part revolution clutch press?
A. Yes, providing the safety distance for locating the trips is adequate.
26. Q. What methods are used to fix the position of two-hand trips or controls?
A. Key-locked control stations, key-locked portable control stands, removable plug-in control stations, portable stand floor location fittings, portable stand bases which establish a safety distance, movable control bars or buttons fixed by fasteners which require the use of special tools to remove.
27. Q. Can a two-hand control be used as a trip on a part revolution clutch press?
A. Yes, the holding time is adjustable and could be set to perform like a two-hand trip.
28. Q. On a two-hand control, what "holding time" is required?
A. None, but to qualify as a "control" rather than a "trip" it must be possible to set a "holding time".
29. Q. Must "holding time" cover the entire period of die closing or until the hazard of die closing ceases at 1/4 inch opening?
a. No, holding time can be set for any period of time during the cycle. Press stopping time is the critical factor in establishing the safety distance for safeguarding means.
(VI) TYPE A&B GATES
30. Q. Is a Type A gate an acceptable safeguard with a two-hand trip or two-hand control without adequate safety distance determined by the appropriate formula?
- 1910.217(c)(3)(I)(e)
A. Yes, the Type A gate alone will satisfy the requirements for safeguarding with any form of press actuation such as foot pedal or control, two-hand trip or control without safety distances, or others such as one-hand trip.
31. Q. Can a Type A gate be opened during the downstroke of the slide?
- 1910.217(c)(3)(ii)(a)
A. No, a Type A gate remains closed.
32. Q. Can a Type B gate be opened during the downstroke of the slide?
- 1910.217(c)(3)(I)(g)
A. Yes, on a part revolution clutch press until slide motion ceases.
33. Q. When manual feeding with hands in dies, can a Type B gate or movable barrier device be used for safeguarding on a full revolution clutch press?
A. Yes, the type B gate or movable barrier device which permits manual feeding on the upstroke is an acceptable safeguard.
34. Q. If a Type B gate is used as a means of safeguarding, can a presence sensing light curtain be used to actuate the Type B gate which subsequently initiates the press to work?
A. Yes, the presence sensing light curtain is then only actuating the Type B gate (the operator safeguard).
35. Q. If a Type B gate can be opened during the closing stroke (on a part revolution clutch press), what safety distance is required to be sure slide motion stops before hands reach the point of operation?
- 1910.217(c)(3)(I)(g) & (c)(3)(ii)(b)
A. A safety distance must be used to insure that the operator's hands cannot reach the point of operation prior to die closing or reaching a point (1/4 inch die opening) where no hazard of die closing exists.
(VII) BARRIER GUARDS & OTHER SAFEGUARDS
36. Q. Can an interlocked barrier guard be installed on a press for protection of an operator manually feeding strip stock through openings in the side or through the movable section of the interlocked barrier guard?
- 1910.217(c)(2)(iv) / 1910.217(c)(2)(v) / 1910.217(c)(2)(vi)
A. Yes, this form of guard may be used; however, the hinged or movable section must be interlocked and can only be opened for clearing a jam or piece of scrap or die changing when the machine has stopped.
37. Q. Can "redundant" or "alternative safeguarding" prescribed by the latest draft ANSI B11.1 revised standard be used in lieu of the OSHA 1910.217(c)(5) "Additional Safeguarding" requirements for part revolution clutch presses (using two-hand control, presence moving or Type B gate of movable barrier device)?
A. Yes, providing a variance has been granted by OSHA under Part 1905 regulations. The approval of the revised ANSI B11.1-1975 standard may warrant a future proposed amendment to grant acceptance to the option of "alternative safeguarding" under OSHA standards. All new or improved means of safeguarding will be subject to future OSHA proposals to bring new technology on stream as soon as proven.
38. Q. Does the use of handtools for feeding qualify as a "hands out of dies" operation?
A. Yes.
39. Q. Is compliance with paragraphs (b)(13) and (b)(14) required when handtools are used for feeding?
- 1910.217(c)(4) / 1910.217(c)(5)
A. No.
40. Q. If presses are operated with "hands out of dies" feeding methods, must safeguarding be provided?
A. Yes.
41. Q. Why?
A. The "hands out of dies" requirement can only be achieved when some form of operator safeguarding is utilized. Handtool feeding, while qualifying as a "hands out of dies" procedure, along with the sliding bolster feeding method, in and of themselves, do not insure that the operator cannot get his hands in the die. These approaches should be used in conjunction with other safety devices; e.g. two-hand trip, Type A and B gates, presence sensing, etc.
42. Q. On presses operated as a "hands out of dies" for feeding must the applicable construction requirements of paragraph (b) be met?
A. Yes.
43. Q. For controls, foot pedals and controls, brakes and safeguard devices?
A. Yes, the standard as promulgated makes no distinction for presses used for "hands out of die" feeding. It is conceivable that a claim can be made that no operator hazard is present on "hands out of dies" operations; therefore, construction requirements need not to be met to insure employer protection from "recognized hazards". The argument, of course, fails on a change to "hands in dies" for a subsequent run. How can a press be reserved exclusively for "hands out of dies" operation and possibly receive a variance?
44. Q. Why are tools required for removal of scrap or stuck work pieces when hand feeding is allowed?
A. Removal and clearing operations are not considered to be as technically difficult as the feeding of dies. The requirement will reduce the number of times that the operator's hands are in the dies and represents a compromise with the former rule for no hands in dies at all times.
45. Q. Can the press control reliability requirement of 1910.217(b)(13) be met on a full revolution clutch press?
A. It is not required on a full revolution clutch press. Claims are being made that such a control criterion can be met on a full revolution clutch press.
46. Q. The new requirements for testing of clutch/brake mechanism, anti-repeat feature, and single stroke mechanism appear to apply to those presses operated on single stroke with "hands in dies" feeding only?
- 1910.217(c)(5)-Additional requirements for safeguarding
A. The only presses excepted from the rule are those that comply with paragraph (c)(5)covering control systems in paragraph (b)(13) and brake monitoring in paragraph (b)(14).
47. Q. Is a sliding bolster by itself recognized as an acceptable safeguard?
A. No.
48. Q. If a sliding bolster is used to feed parts, are two-hand controls required to meet the safety distance requirements?
A. Yes.
(VIII) SAFETY DISTANCE
49. Q. Where is the safety distance measurement taken from? The die or the edge of the bolster or slide?
A. The safety distance is measured from the point of operation of the die (a recognized hazard). The die dimensions may be less than or greater than the size of the slide or bolster.
50. Q. There are different formulas for calculating the safety distance on part revolution clutch machines using two hand control and full revolution clutch machines using two hand trips. What is the significance of the sub letters Ds, Dm, Ts, and Tm?
A. Different sub letters are used to aid users in recognizing that two separate formulas are used for calculating safety distance depending on the type of clutch.
51. Q. When the safety distance is calculated using the formula, what amount of supplemental distance (margin) is required to determine the point at which controls or trips are located?
A. None; however, it is expected that an additional (margin) distance will be added to allow for some brake stopping time deterioration or slide stopping point tolerance.
52. Q. What is "separation"? What is "safety distance"? Are they the same?
A. "Safety distance" is the proper distance from the controls to the point of operation, as defined in ANSI B11.1-1982, -1988, and the 1994 ANSI draft proposal of April 24, 1994. "Separation" is the term used in ANSI B11.1-1982, -1988, and the April 24, 1994 draft revision, which compares with the term "separation" OSHA uses to refer to the distance between an operator's hand controls to require the use of both hands to operate the press.
53. Q. What is meant by separation when describing the position or arrangement of two hand trips and two-hand controls?
OSHA recognizes the use of "separation distance" when applied to locating two-hand control buttons remote from each other to discourage attempts at one-hand actuation.
54. Q. What is the source of the 63" hand speed constant?
A. European studies by Dr. O. Lobl of Sweden which determined a safety distance for use in the regulations of foreign countries.
55. Q. Which formula is proper for finding the safety distance on a part revolution clutch press with two-hand controls?
- 1910.217(c)(3)(vii)(c)
No formula for calculating safety distance on a part revolution clutch press actuated by a two-hand trip is provided. The time recommended would be that for the die closing stroke.
56. Q. Why is the position of approximately 900 of crankshaft rotation chosen for determining brake stopping time?
The longest possible stopping time should be used when calculating the safety distance. The point in the stroke near point of maximum speed or half way down was considered to be the best place to measure the longest time for stopping the slide. This conclusion is currently being challenged based on testing by several people.
(IX) RECORD KEEPING
57. Q. How long must the records required by Section 1910.217(e) be kept?
A. Section 1910.217(e) makes no provision for record retention period.
58. Q. Are Federal agencies required to report injuries to press operators?
A. No.
59. Q. Must a written record be kept of pull-out adjustment and testing for each shift change, operator change, or new die set-up?
- 1910.217 (c)(3)(iv)(d)
A. The record keeping requirements of 1910.217(e) are applicable.
60. Q. If an employee is injured by a broken piece/part thrown from the die, must a report be sent to the OSHA Directorate of Safety Standards?
A. No, only injuries to employees which occur within the point of operation are to be reported.
61. Q. Where did the weekly period for inspections come from?
A. ANSI B11.1-1971 explanatory column accompanying requirements for inspections.
62. Q. What periods are recommended by the ANSI B11.1-1971 for press inspections?
A. B11.1-1971 recommended weekly, monthly, or possibly longer periods for press and safeguarding inspections, testing, and maintenance.
63. Q. Are records required to be kept?
A. Yes, B11.1 requires records of inspections.
64. Q. For how long?
A. No definite retention periods are prescribed by OSHA for power press records.
65. Q. Are periodic inspections and records required for all presses even when operated on continuous or with no hands in dies?
A. Yes, every press is required to be inspected and maintained to protect the safety of operators, die setters, and others.
66. Q. Is it necessary to report minor injuries such as a scratch or pinched finger when feeding a die?
A. No, only report those injuries which qualify for listing on the OSHA Form 200.
(X) MINIMUM REQUIREMENTS FOR POWER PRESS OPERATORS TRAINING
The operators of mechanical power presses must be trained in all phases of the operation of the equipment and its capabilities and limitations, and:
A. All press controls and how to use them.
B. The operator must be informed of the safety guards and devices incorporated on the machine and the correct use of each.
C. Each operator must be instructed in the use of tools for removing stuck work and the use of swabs, brushes, or oil cans for lubricating dies and stock.
D. Press operators will need to understand why, when, and how to use personal protective equipment, such as safety glasses, gloves, safety shoes, and hearing protection.
E. The storage of parts, tools, or other objects on dies, die sets, bolster plates, or press components not designed to retain them; present hazards of falling on operators; and possible pinch points with moving components. Operators must be aware of these hazards, as well as the basic housekeeping around the press areas.
F. Press operators must be instructed not to operate the press until the press has been checked and tested several times prior to production operations. He/she should report any problems which he/she observes to the proper person.
G. Employees who are going to operate presses must receive a minimum of 8 hours* on the job training under supervision prior to being assigned to operate the presses. *this could be up to 2 weeks or more, depending on the complexities of the operation.
(XI) MINIMUM TRAINING REQUIREMENTS FOR PRESSROOM SUPERVISORS
A. The foreperson must be informed of his responsibilities to the employer and the employees who work with him/her.
B. He/she must know the hazards of power press operations and their set-up and maintenance.
C. The pressroom foreperson must be knowledgeable of what the safety guards and devices are intended to do and the correct adjustments and use of each.
D. He/she must check each set-up and be sure that all operators are instructed in safe power press operations before they start work.
E. It is his/her responsibility to insure that correct operating procedures are being followed.
F. The foreperson must see that all maintenance is performed and that presses are in safe repair prior to
their operation. As the employer's representative, the pressroom supervisor is responsible for the
training and operations of the employees under his/her control.
