by clicking the arrows at the side of the page, or by using the toolbar.
by clicking anywhere on the page.
by dragging the page around when zoomed in.
by clicking anywhere on the page when zoomed in.
web sites or send emails by clicking on hyperlinks.
Email this page to a friend
Search this issue
Index - jump to page or section
Archive - view past issues
FLEXO Magazine : March 2008
52 FLEXO MARCH 2008 www.flexography.org PLANTS & PROCESSES OSHA internal database will be searched for employer citation and fatality/accident history to determine the level of inspection scrutiny. At the opening conference, the OSHA 300 logs for the past three to five years (five years is the regulatory retention period) will be reviewed to identify recorded amputations associated with machinery and equipment. The inspector will also verify with the employer whether any machinery and equipment that could cause amputations is present in the workplace before proceeding with the inspection. If such equipment is identified, the in- spector will conduct an inspection of the machinery and equip- ment with particular attention to potential employee exposure to nip points, pinch points, shear points, cutting actions, mov- ing parts, and other point(s) of operation. The NEP also instructs the inspector to consider and pay par- ticular attention to employee exposures during any of the follow- ing activities: Regular operation of the machine. Setup/threading/preparation for regular operation of the machine. Clearing jams or upset conditions. Making running adjustments while the machine is operating. Cleaning of the machine. Oiling or greasing of the machine or machine pans. Scheduled/unscheduled maintenance. Locking out or tagging out. IMPACT ON PRINTERS Since the revised NEP became effective, a number of printers have already stated that they have received inspections by OSHA specifically due to the NEP program, or have encountered addi- tional inspection scrutiny as a result of the NEP criteria. Because any printer segment identified by the targeting criteria is now vulnerable to an OSHA inspection, it is important that all equipment guarding and safe equipment procedures be reviewed before an inspection occurs. While the main focus of the NEP will be on printing presses, all equipment, including bindery equipment, at the facility is susceptible to examination during an inspection. What can printers do? First, they should ensure that operators have adequate initial and refresher training on operating press and postpress equipment safely. Emphasis should be placed on identifying the hazards of that specific piece of equipment, such as showing ingoing nip points, sharps, etc. as it relates to safely performing production-related adjustments, clearing jams, and cleaning. Employee training and a healthy respect for production equipment hazards have been shown to reduce workplace acci- dents long term. If possible, document the training, even on-the- job training. In the event OSHA investigates an accident, printers can demonstrate good faith efforts in training to prevent operator error and then possibly negotiate for lower penalties. Ensure that a machine guard is protective, but also functional. Not only must press and postpress equipment be adequately guarded, so must conveyors with exposed nip points, rollers, sprockets, and belts less than seven feet above the floor. OSHA has stated that guard bypass requires lockout, unless an equally protective method is provided. The entire printing industry en- joys the flexibility of the inch-safe-service method as it offers an equally protec- tive method for production-related adjustments, clearing jams, and cleaning under OSHA letters of Interpretation. Finally, a review of your written lock- out/tagout program should be undertaken to ensure that it is complete and addresses common major and minor servicing activities. To comply with the standard, printers must meet several basic requirements which include a hazard assessment of energy types and sources, the development of a written program detailing the specific procedures and when they will be used for locking or tagging out equipment, including machine specific procedures and an employee training program. Make sure there is an adequate verification step for ensuring that equipment has been properly de-energized before servicing. Equipment operators must be familiar with what minor servicing activities can be performed under the inch-safe-service method and those that require lockout. ABOUT THE AUTHORS: Robert Fricke is an environmental & safety consultant with 25 years experience in assisting the printing industry. Rick Hartwig is the manager of environmental health and safety affairs for PIA/GATF and has more than 21 years experience in the printing industry. In support of the revised NEP and as part of available outreach materials, OSHA revised its publication, OSHA 3170: Safeguarding Equipment and Protecting Employees from Amputations, which focuses on amputation prevention and covers many different types of equipment and circumstances including printing equipment. The publication can be down- loaded at http://www.osha.gov/Publications/osha3170.pdf. For a copy of the revised NEP, visit http://www.osha.gov/pls/oshaweb/ owadisp.show_document?p_table=DIRECTIVES&p_id=3469. Because any printer segment identi- fied by the targeting criteria is now vulnerable to an OSHA inspection, it is important that all equipment guarding and safe equipment procedures be re- viewed before an inspection occurs.