September 16, 1992

Mr. John Runyan
Director of Political Affairs
Printing Industries of America, Inc.
100 Dangerfield Road
Alexandria, Virginia 22314

Dear Mr. Runyan:

This is in further response to your letters of August 13, 1991 and January 3, 1992, requesting interpretation and clarification of Occupational Safety and Health Administration (OSHA) standards at 29 CFR 1910.147, 1910.212, and 1910.219 as they apply to printing presses which function under two separate modes of operation. One operational mode occurs when the equipment is used in normal production operations and the OSHA standards on machine guarding apply. The other mode occurs when the equipment is being serviced and maintained and the OSHA standard on the control of hazardous energy (lockout/tagout) at 1910.147 applies.

From the time of your meeting in December 1991 with former Assistant Secretary Scannell, members of my staff have conducted a more in-depth review of the issues you raised, including points on which apparent conflicts existed, especially those involving the performance of press tasks requiring main drive motion, i.e., cleaning plates and lubricating cylinders, replacing blankets and plates, etc. During the meeting, several ANSI and OSHA standards which cover essential aspects of safe printing press and binding equipment operation were discussed. These standards relate to the design of printing presses, binding and finishing systems and their respective control equipment (ANSI B65.1 and B65.2), guarding during normal production operations (OSHA 1910 Standards, Subpart O), as well as lockout/tagout (29 CFR 1910.147). During that meeting, the specific standards of Subpart O, also applicable to printing presses, were likewise discussed. These related to general machine guarding requirements (29 CFR 1910.212) and to mechanical power-transmission apparatus (29 CFR 1910.219).

Since these discussions were intended to help clarify the interpretation of these OSHA standards with respect to their application to printing presses, a summary of the salient points is presented in the following paragraphs. Also, in the enclosure to this letter, the applicability of the OSHA standards 29 CFR 1910.147, 1910.212, and 1910.219, is discussed further.

The variety of printing presses into which different technologies, spanning many years, are incorporated requires that each machine or piece of equipment be analyzed to determine the type of operational modes being conducted, the type of safeguarding used to protect employees during those operational modes and the need for additional safety measures to ensure compliance with OSHA safety standards at 29 CFR 1910.147, 19190.212, and 1910.219.

The machine guarding standards in Subpart O of the general industry standards apply to the safeguarding of all machines, including printing presses. Specifically, 29 CFR 1910.212 applies to the safeguarding of all machines, and 29 CFR 19190.219 deals with the safeguarding of power transmission apparatus. These standards require safeguarding of machines and equipment to preclude employee injury during normal production operations, that is, when a machine or piece of equipment is being used to perform its intended production function. (See the definition of normal production operation in 1910.147(b)).

On the other hand, the OSHA standard for the control of hazardous energy (lockout/tagout) requires the safeguarding of machines and equipment whenever servicing or maintenance is being performed. This safeguarding normally consists of stopping the machine or equipment, isolating it from its energy source(s), locking or tagging out the energy isolating devices, relieving or releasing any stored or residual energy and then verifying that the machine or piece of equipment is safe to work on. All safeguarding activities must be conducted in accordance with procedures developed and documented by the employer for the purpose.

At times, however, OSHA recognizes that some minor servicing, that is, servicing which must be conducted frequently, may have to be performed during normal production operations, and a lockout/tagout exception is allowed. In a note following paragraph 29 CFR 1910.147(a)(2)(ii), this exception is stated:

"Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part)."

In the printing industry, we understand that the term "minor servicing" includes, among others, tasks such as clearing of certain types of paper jams; minor cleaning, lubricating and adjusting operations; certain plate and blanket changing tasks; and, in some cases, paper webbing and paper roll changing. Generally speaking, "minor servicing" is considered to include those tasks involving operations which can be safely accomplished by employees and where extensive disassembly of equipment is not required. Such tasks will be identified through the hazard analysis required by the lockout/tagout standard.

In order to perform maintenance or servicing, in which an employee bypasses guards which are required by either 1910.212 or 1910.219, or otherwise becomes exposed to the hazards of machine start-up or to the unexpected release of hazardous energy, the OSHA lockout/tagout standards apply. If no such exposure occurs (either because of the methods in which the minor servicing is performed or because special tools, techniques, or other protection is used), lockout/tagout is not required, provided the employer uses alternative measures which enable an employee to perform minor servicing without being exposed to a hazard. Under no circumstances is an employee ever permitted to place any part of his or her body within a hazardous area, such as the point of operation, while the equipment is running or energized (and alternative measures have not been taken), or around power transmission apparatus.

During minor servicing, an employer is considered to have met the requirement for providing effective alternative protection by the use of special tools or techniques. Effective alternative protection may not include, by themselves, simple pushbuttons, selector switches, and other control circuit type devices which lack a control logic such as an interlocked arrangement which provides a single operator with exclusive control. One such method which does appear to offer effective alternative protection is the inch-safe-service technique used for the main drive control. This technique is consistent with the use of controls specified in the ANSI standards B65.1 and B65.2 for web and sheet-fed printing presses and binding and finishing equipment respectively for which, as a minimum, a stop/safe/ready function must be available at designated control stations. Limiting some control stations to the "inch" function only is not permitted. Also, the stop/safe/ready switch must not serve as the lockout disconnect when lockout is performed. A brief summation of the essential elements of that procedure together with the observance of certain safe work practices is as follows:

1. Before any minor servicing is performed, the machine must be stopped, and its drive control must be on STOP/SAFE. Servicing and/or maintenance as defined in 29 CFR 1910.147(b) must not be conducted when the components of the machine are moving.
2. Consistent with the requirements contained in 29 CFR 1910.147(f)(1) for testing or positioning a machine during servicing, procedures to inch a machine require all employees be positioned so that they are not endangered by the re-energization or startup of the machine. In addition, all tools or other implements used during the servicing must be positioned so that no hazard is created for employees. On presses attended by more than one operator or when it is possible for another employee to enter the frame or be obscured from view of the operator, suitable safety alerting signals must be employed.
3. By use of the INCH control, the components of the machine are moved to their desired position. Immediately thereafter the drive control is placed on SAFE by each employee working in a hazardous area before beginning or resuming the minor servicing.
4. Steps (b) and (c) are repeated as necessary until the minor servicing is completed.

When minor servicing is conducted and the use of the STOP/SAFE drive control is the method of safeguarding employees, the controls to make READY, to INCH, and to START the machine must be under the exclusive control of the authorized person(s) who is/are performing the servicing. If there is a likelihood that the START or INCH controls can be inadvertently activated by any employee, including the one performing the minor servicing, it is necessary that the permissive period be immediately canceled by depressing the STOP/SAFE push button, and not wait for the conclusion of the permissive period to conduct the minor servicing. The STOP/SAFE control used for the inch-safe-service procedure shall be designed and installed to preclude energization or startup of the equipment by any other control until all SAFE's are canceled.

When more than one employee performs a particular servicing or maintenance operation on a machine or equipment, the servicing or maintenance generally is not considered minor in nature, and the machine or equipment must be locked out or tagged out in accordance with §1910.147. However, if two or more employees perform separate servicing operations on a machine or equipment at the same time, the combined servicing operation may be considered minor servicing only when each separate servicing operation is routine, repetitive and integral to normal production operations, and when alternative effective protection is provided for the servicing employees. Alternative effective protection means:

1. Servicing is conducted when the machine or equipment is stopped, and
2. Each servicing employee has continuous, exclusive control of the means to start the machine or equipment, and
3. Safeguarding is provided to each servicing employee to prevent exposure from the release of harmful, stored, or residual energy.

The electrical standards at 29 CFR 1910 Subpart S contain requirements for employee safety relative to electrical hazards in the workplace. Paragraph 1910.332(a) requires that employees, who service machines or equipment and who face a risk of electrical shock or other electrical hazards that are not reduced to a safe level by the electrical installation requirements of sections 1910.303 through 1910.308, must be trained in electrical safety-related work practices, as required by sections 1910.331 through 1910.335.

OSHA will provide copies of this response to all OSHA field offices. Compliance Officers (CSHOs) will be instructed to use this response for reference when evaluating the safety of printing presses during workplace inspections.

Thank you for your patience and cooperation in this matter.

Sincerely,

Patricia K. Clark, Director
[Directorate of Enforcement Programs]

Enclosure

[Corrected 4/27/2004]

The following is a general summation of the application of the OSHA standards, 29 CFR 1910.147, 1910.212, and 1910.219 for pressroom workers:¹

1. When maintaining or repairing equipment, always place the machine in SAFE condition and LOCK OUT the power to avoid the danger of serious injury to yourself and other workers.
2. Before maintaining or repairing any equipment, lock out the main electrical power disconnect, bleed off all hydraulic and pneumatic systems, secure all parts that can fall, and take any other specific precautions required for the particular equipment.
3. A warning tag or power box lock should be installed to prevent others from starting the equipment, before maintenance is completed and to alert them that maintenance or repair work is in progress. When not in use, turn the equipment OFF.

Thus, to be more explicit, it is consistent with the application of OSHA standards to printing presses that minor servicing operations (such as clearing of certain types of paper jams; minor cleaning, lubricating, and adjusting operations; certain plate and blanket-changing tasks; and, in some cases, paper webbing and paper roll changing) can be accomplished using the inch-safe-service method, where the safety practices inherent under conditions of normal production operations will prevail.

However, when service and maintenance operations are performed which lead to other workplace hazards, such as unexpected energization of machines or equipment or unexpected release of energy, the OSHA lockout/tagout requirements apply. Examples of such typical servicing and maintenance activities requiring lockout/tagout procedures are as follows:

1. Operations where auxiliary motors and pile motors are not disabled by the safe button and where the operator cannot maintain exclusive control of the machine or machine elements such as when cleaning frames and braces, cleaning the feeder, and delivery on sheet-fed presses, or when cleaning the reel stand and other parts of the infeed on web presses, or when cleaning or replacing air filters used to supply ventilation for toxic or flammable materials or heat generating electrical equipment.
2. Operations that require the machine operator to remove major parts of the equipment such as panels or other barriers that restrict access to moving mechanical parts or energized electrical equipment; or to perform extensive work without removal of such components; or to perform work requiring the operator to leave the immediate area containing the operating controls where exclusive control by the operator is required. Thus, for example, roller removal would require lockout/tagout when two people are required and/or there are no quick release sockets which would permit safe roller removal by one person.

¹ Adapted from "Pressroom Safety Manual," National Printing Equipment and Supply Association, Inc.; Reston, Virginia 22091-4367. [ back to text ]