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Industry regulations => OSHA => Topic started by: Flying Colors on September 03, 2014, 12:10:20 PM
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We recently had a OSHA visit. They found a few things that we need to get better but all in all it went pretty well.
The main issue we have is with Machine Guarding. Currently, we have the standard emergency bars/cords that everyone else seems to have.
The inspector said we need to have the machine guarded so someone cannot crawl through any opening. I explained that this is the industry standard but the inspector did not seem to be interested in that.
Anyone else have this issue before and is there some sort of exemption we can file?
Mark
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You can try the lock-out tag-out route. Years ago they made us put guards on the back of the dryer over the rollers. He claimed that this was a "nip point"
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Dude that SUCKS Mark!!!! So did he have a issue with all your automatics?
That just doesn't seem right(not that I have a clue). It would be hard to believe that the manufacturers of ALL automatics out there would create a machine that would create a immediate OSHA violation.... Hopefully 244 will chime in, I'd wager he would know a thing or two about this.
Please keep us updated Mark, if your inspector is correct we all have something to be worried about! :-
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What is curious to me is that OSHA doesn't go after the mfg (ignorance on my part; could be some territorial issue) Long ago, when some very unfortunate person got his skull crushed on an Oval due to a by-passed safety; OSHA made that company lock the screen side of all of the machines behind fencing. A dead mans switch that cut power to the machines was the only way to get behind the machine. Someone actually died and yet no action taken against the equip mfg. themselves to my knowledge.
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Dude that SUCKS Mark!!!! So did he have a issue with all your automatics?
That just doesn't seem right(not that I have a clue). It would be hard to believe that the manufacturers of ALL automatics out there would create a machine that would create a immediate OSHA violation.... Hopefully 244 will chime in, I'd wager he would know a thing or two about this.
Please keep us updated Mark, if your inspector is correct we all have something to be worried about! :-
Each inspector translates the guidelines differently. We do offer for our machines a full wrap around laser safety system that inspectors way more critical than OSHA has approved. Great for safety but a real pain in production. You can't even card the screens without causing the press to stop.
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Thanks for the insight Rich!
Mark are you part of SGIA? Maybe they have some resources to help you. They have a whole new package they are advertising about compliance.
I'd contact Printwear and Impressions/ISS(keep in mind they have the Orlando show this week) also. Not that they would have any answers, but it would be in their best interest to cover(read- add pressure) a situation like this. If this inspector has his way and his "method" of inspecting spreads to other inspectors it could become a big issue for a lot more of us!
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Rich beat me to it but like he said it's all in the inspectors interpretation of the CFR, not just OSHA but with most regulating agencies. None of them like to proven wrong so it becomes a touchy situation disputing an issue plus I feel a lot of it is job justification. There are provisions under some situations if you can prove the request is unreasonable they will accept a different resolution but if the inspector is hard headed it can become a nightmare.
You may be able to request a review and have another inspector look at the situation, but depending on how much seniority the inspector has it could open a can of worms. If he feels you are trying to side step the situation and has some authority he could make your life difficult. If you are in good standing with the regulating body, prove to them it's not an issue, provide them with another solution and get a reasonable person hopefully they will work with you. But you have to present them with hard facts not just shop talk.
Like Rich said a laser safety curtain around each press would work but would be costly and hinder production. Same would apply to a cage around the press, I believe that's almost what they do in Canada. Or maybe you could paint a wide yellow stripe around each press with warnings stating do not enter and add a flashing light above each press tied into the indexer. So when the machine is running the light is flashing.
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I've seen the thick yellow painted line many times so HOPEFULLY that may be a good compromise that works.
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Thanks everybody for the information and advice, we have not had our closing conference yet so I will find out more then.
We were actually visited by MiOSHA not OSHA, Michigan's version and obviously they have similar rules but from what I can gather a little harsher in certain areas.
Rich- How much is the laser system?
Alex- We are not part of SGIA.
Mark
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What is curious to me is that OSHA doesn't go after the mfg (ignorance on my part; could be some territorial issue) Long ago, when some very unfortunate person got his skull crushed on an Oval due to a by-passed safety; OSHA made that company lock the screen side of all of the machines behind fencing. A dead mans switch that cut power to the machines was the only way to get behind the machine. Someone actually died and yet no action taken against the equip mfg. themselves to my knowledge.
My understanding is that OSHA (and I assume the state versions) is only there to protect the safety of employees.
The equipment manufacturers would similarly be held responsible by OSHA guidelines for the equipment that their employees used, not what they are producing.
On a similar note, in a mom and pop with no employees, there is not the same scrutiny.
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Thanks everybody for the information and advice, we have not had our closing conference yet so I will find out more then.
We were actually visited by MiOSHA not OSHA, Michigan's version and obviously they have similar rules but from what I can gather a little harsher in certain areas.
Rich- How much is the laser system?
Alex- We are not part of SGIA.
Mark
The laser system comes two ways. One is a scan laser at the load/unload station and the other is a complete wrap around the press including the scanner. Price for both is around $8,000. We also have to change the program at the same time hence we only do it on M&R machines.
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SGIA did just offer am OSHA seminar. State could be different though.
What about systems that stop the servo motion if a certain amount of resistance is detected? Two mfg have this feature.
Sent from my XT907 using Tapatalk
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SGIA did just offer am OSHA seminar. State could be different though.
What about systems that stop the servo motion if a certain amount of resistance is detected? Two mfg have this feature.
Sent from my XT907 using Tapatalk
That can be done if you don't want speed and its a hell of a lot of stopping the press. I have seen this in the field and its a disaster but that's just my opinion.
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SGIA did just offer am OSHA seminar. State could be different though.
What about systems that stop the servo motion if a certain amount of resistance is detected? Two mfg have this feature.
Sent from my XT907 using Tapatalk
That can be done if you don't want speed and its a hell of a lot of stopping the press. I have seen this in the field and its a disaster but that's just my opinion.
We have that feature on our press and it actually works pretty well.... If the press is running and hits you, you will get a bruise but it wouldn't knock you over or anything. Has no effect on the speed whatsoever.
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SGIA did just offer am OSHA seminar. State could be different though.
What about systems that stop the servo motion if a certain amount of resistance is detected? Two mfg have this feature.
Sent from my XT907 using Tapatalk
That can be done if you don't want speed and its a hell of a lot of stopping the press. I have seen this in the field and its a disaster but that's just my opinion.
We have that feature on our press and it actually works pretty well.... If the press is running and hits you, you will get a bruise but it wouldn't knock you over or anything. Has no effect on the speed whatsoever.
What is the maximum index speed on your machine? All machines have mass that must be brought from a stop to a pretty good speed in a short distance. The force to get the inertia moving takes torque which if set too low will trip on start up so I am curious why this is not the case on your machine? I know on the other machine that does this it uses many little motors driving very little mass. on yours there is one drive motor and a lot more mass. Much lower index speed maybe?
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It seems to me that something like a chop saw is a hell of a lot more dangerous than a screen printing press,
and yet because it's not really possible to operate completely safely in the field it receives far less scrutiny.
IE don't block the guard and you're good to go.
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Fastest we have ever been able to run it was 1240/hr.(may of been 1204/hr.) and that glory was short lived, we just couldn't keep up. So if it could go faster than that great, but in the real world there is no real reason it would need to.
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Fastest we have ever been able to run it was 1240/hr.(may of been 1204/hr.) and that glory was short lived, we just couldn't keep up. So if it could go faster than that great, but in the real world there is no real reason it would need to.
And at 1240 per hour you are sure the indexer wont hurt you pretty badly?
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Fastest we have ever been able to run it was 1240/hr.(may of been 1204/hr.) and that glory was short lived, we just couldn't keep up. So if it could go faster than that great, but in the real world there is no real reason it would need to.
And at 1240 per hour you are sure the indexer wont hurt you pretty badly?
Yes. We could be printing 20/hr or 1200/hr, the force that it indexes with dosent change. Dwell time, print size, flashing, ect. is what slows or speeds up the machine.
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I've seen what happens when the servo accelerations are set incorrectly and a machine reverses quickly. And this was on a "little" 1600oz servo on a cnc machine. Much smaller than the motors that index our presses.
Reverse indexing a press instantly will not be good for the long term longevity of the gears or servo.
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It doesn't "reverse". It just goes dead. Maybe I'll sacrifice my hip after lunch here and make a video for you guys.
Mark, none of this helps you sorry man. Is there any way you can have the inspector take a closer look and maybe "index" him....? ;D
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Mark, none of this helps you sorry man. Is there any way you can have the inspector take a closer look and maybe "index" him....? ;D
There's a certain image floating around that may illustrate exactly what you're talking about here...
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Like when I tossed a mannequin into the swirling Death Machine?
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Just throwing this out there but it wouldn't be that hard to add a safety system to the brand X machine, the green one and posablely the blue one. It could be done with light beams or maybe even a pull cord around the press. It would be costly, I know it could be done on the brand X.
Another option would be the safety zones and a training program where anyone entering the shop area would have to take an approved class developed by you that would cover the dangers. The person would have 2 hrs of training, sign off on the materials and get a card with refresher training every year. Like forklift certification.
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The S.roque "safe servo" isn't going to just halt like the MHM oval I don't think, Alex has chimed in on that. My understanding is it prevents major injury. If you just threw your arm into it it might break it I imagine, depending on where you threw it into, but would not "follow through" and complete the index, ripping said arm off or dragging you in. You would get hurt but not stuck inside the machine's workings.
If it's really needed for MI OSHA, maybe you could just make a hexagonal shape of gates all around the press out of wood or metal. Nobody could "crawl into" it during operation but you could lean over to scoop ink and the ops could just swing the gates open when the safety bars/cables are disengaged for changeovers. Heck, if you have safety bars that swing horizontally you could hook up the gates to them, just bolt a post under the hinging part of the safety bar. That wouldn't be bad, no one could get in there unless the safety was engaged, or duck under the bars with the machine in operation as I've heard in one or two horror stories.
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Ok so I broke my "work time TSB ban" and look what happens. I start posting and end up making a video! On top of that all of us here has a good laugh for 30min after watching the video a few dozen times...
Enjoy fellas....
(http://i845.photobucket.com/albums/ab14/twincitytees/th_VID_20140904_1335581_zps5a6e3838.mp4) (http://i845.photobucket.com/albums/ab14/twincitytees/VID_20140904_1335581_zps5a6e3838.mp4)
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That's a great safety feature. Thx for the vid I was really wondering how that worked in real life.
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That'll leave a mark.
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That's what I was thinking... can we see the bruise?
That looked like about as hard as the Javelin hit me when I got indexed... I thought it broke my arm.
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Oh ya, you will feel it that is why I put my fat ass in there! ;D
I probably made it look a bit more dramatic than it was because I knew it was coming. But all I was trying to illustrate is how it goes "dead".
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Alex-
This does help, the brainstorming is great and I will bring up all these ideas (the least expensive ones first) at the closing conference and get the inspectors opinion.
I think I will put your video on a big screen for demonstration purposes and tell him to go to Minnesota next.
Mark
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Alex-
This does help, the brainstorming is great and I will bring up all these ideas (the least expensive ones first) at the closing conference and get the inspectors opinion.
I think I will put your video on a big screen for demonstration purposes and tell him to go to Minnesota next.
Mark
Ya, lets go ahead and NOT do that! Inspectors give me panic attacks. I have rental properties and have been put through the ringer before by the city and the inspectors. Oddly enough we had the fire inspector here on Tuesday(ruined my whole weekend worrying about it) he was super cool, only have 4 things I need to fix!
Really wish I could be of more help.
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Ok so I broke my "work time TSB ban" and look what happens. I start posting and end up making a video! On top of that all of us here has a good laugh for 30min after watching the video a few dozen times...
Enjoy fellas....
([url]http://i845.photobucket.com/albums/ab14/twincitytees/th_VID_20140904_1335581_zps5a6e3838.mp4[/url]) ([url]http://i845.photobucket.com/albums/ab14/twincitytees/VID_20140904_1335581_zps5a6e3838.mp4[/url])
Dude, WTF. Your HARD CORE.
I'm still not sure I would want to get hit in the head with that, & I wander if that's the inspectors problem/ worry.
I know someone that was hit in the head, it wasn't pretty, he's alive but, very lucky.
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The guys from Forward Printing where telling me about this in LB. I asked him if he would demonstrate and he politely declined. My hat is off to you for making the sacrifice and I got a good laugh out of it as well.
I have a rule for my operators that if they bend over at the load or unload station during production will result in their immediate termination. I have had to do this once after the pallet clipped his nose, he was extremely lucky.
Chris
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So I know this was from a few days ago, but Mark did any good news come of the meeting? Were they somewhat cool with understanding the industry "standard" is basically safety bars/wires?
Sidenote, I ended up being bruise free from my little demonstration! Anyone want proof of that, PM me your credit card number and I'll get you some pics of my duff! 8) ;D ;D ;D
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the easy thing with the fire inspection is to leave a crapload of extension cords plugged in and take down your fire extinguishers...they will tell you those two things and move on.
They weren't happy I deadbolt the back door in off hours, but the city and county police recommended it. It's unlocked and "single motion" exit while the building is occupied. I try and lock all doors between areas to slow down any break-ins.
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Alex, that video is halarious! Go see the Chiro and get that back re-aligned hahahahahhahahahahah. Betchya had to change your shorts after that one, lol ;D
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Sounds like another credit card scam to me. I bet I don't get any pics or videos, but I'll try anyway. How much?
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Sounds like another credit card scam to me. I bet I don't get any pics or videos, but I'll try anyway. How much?
Oh, never had anyone interested, let me ask my wife and get back to you... :D
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No answers yet Alex, we still have not had the closing conference.
Mark
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We had our closing conference yesterday and it was not good news. The inspector said we have to have all of the automatics guarded so someone cannot put their hand into the press.
I told him that I respectfully disagree with his interpretation of the rule. I asked him if we could put some cones or yellow tape down to alert people of danger areas and he said that would not be sufficient.
Our next step is to have their Consultation Department down here to see if they will give us a different interpretation of the law.
I also asked him, since he is from MiOsha, if MiOsha's machine guarding rules were more stringent than Federal OSHA. The inspector said no, even if he went off of the Federal OSHA laws he would still report us as a violation.
I did find out exactly what he wants guarded. He is saying there is a Pinch Point at every print head. The pinch point is where a indexing the pallet crosses underneath the frame.
Mark
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We had our closing conference yesterday and it was not good news. The inspector said we have to have all of the automatics guarded so someone cannot put their hand into the press.
I told him that I respectfully disagree with his interpretation of the rule. I asked him if we could put some cones or yellow tape down to alert people of danger areas and he said that would not be sufficient.
Our next step is to have their Consultation Department down here to see if they will give us a different interpretation of the law.
I also asked him, since he is from MiOsha, if MiOsha's machine guarding rules were more stringent than Federal OSHA. The inspector said no, even if he went off of the Federal OSHA laws he would still report us as a violation.
I did find out exactly what he wants guarded. He is saying there is a Pinch Point at every print head. The pinch point is where a indexing the pallet crosses underneath the frame.
Mark
You will need the full wrap system we offer our customers. Our system is about $8,000.00 and requires a program change. We can offer the system but no programming for other brands. That will be up to them. If you want to discuss I will be back in my office on the 30th. Feel free to call.
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That is horrible news Mark! I'll curse their name/organization for you from here, and quietly so as not to draw attention to myself.
In all seriousness though, one would think if this is a issue it would of come up publicly, in a trade mag. or on a forum before.... I have found the hard way it isn't always the best practice to question/challenge an inspector but is it possible to ask if this inspector in particular has EVER inspected a screen printing shop before? Or if MiOsha has ever inspected one ever before also I guess. If anything this would give you an idea of what someone has had to do before for these guys. Basically what MiOsha is saying is that 99.99% of autos out there create an immediate OSHA violation once installed? That just seems so absurd to me.
It would also be interesting to know what if anything the new $22M Teespring plant in KY will handle this, forgot the exact number but I want to say they are installing 50 or 60 autos. One would think they would try to be proactive to avoid issues with OSHA.
244/Rich- I know you probably can't be specific with names and whatnot, but is this a issue that you have seen at all before? I'm not trying to point fingers or anything, just on this whole forum you are probably the most experienced/knowledgeable with this if sometimes it poses a issue to some inspectors.
Just in case- anatolhelp, colintas, Baron265 Have you guys ever seen anything like this before?
If for some odd reason there is anything I can do Mark let me know. You can use my video and show the inspector the press doesn't kill anyone.... If you do, please have your art dept. blur out the back of my shirt so I don't draw any attention!
Good luck buddy!
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That is horrible news Mark! I'll curse their name/organization for you from here, and quietly so as not to draw attention to myself.
In all seriousness though, one would think if this is a issue it would of come up publicly, in a trade mag. or on a forum before.... I have found the hard way it isn't always the best practice to question/challenge an inspector but is it possible to ask if this inspector in particular has EVER inspected a screen printing shop before? Or if MiOsha has ever inspected one ever before also I guess. If anything this would give you an idea of what someone has had to do before for these guys. Basically what MiOsha is saying is that 99.99% of autos out there create an immediate OSHA violation once installed? That just seems so absurd to me.
It would also be interesting to know what if anything the new $22M Teespring plant in KY will handle this, forgot the exact number but I want to say they are installing 50 or 60 autos. One would think they would try to be proactive to avoid issues with OSHA.
244/Rich- I know you probably can't be specific with names and whatnot, but is this a issue that you have seen at all before? I'm not trying to point fingers or anything, just on this whole forum you are probably the most experienced/knowledgeable with this if sometimes it poses a issue to some inspectors.
Just in case- anatolhelp, colintas, Baron265 Have you guys ever seen anything like this before?
If for some odd reason there is anything I can do Mark let me know. You can use my video and show the inspector the press doesn't kill anyone.... If you do, please have your art dept. blur out the back of my shirt so I don't draw any attention!
Good luck buddy!
I have seen this more than you would imagine. We do not ship machines into France or Montreal Canada without the full system. M&R has spent millions of dollars on this issue and finally came up with a system that is acceptable to most if not all inspection procedures. It is quite expensive but definitely protects the operators and has passed the most strenuous test thrown at it. We showed it to the U.S. customers at the SGAI last year. When we offer it to our customer base they say our press is too expensive so we make it an option you take or sign off you don,t want it. If you get inspected expect this to be an issue and hopefully your supplier of choice is ready to help with a solution!
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I have seen this more than you would imagine.
Well thanks for the bad news answer(can you read my sarcasm?) Seriously though, thanks for the insight Rich!
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Update on the MiOsha issues we have been dealing with. Sorry for the length but this is going to be a long post...
What began as a single visit morphed into 4 separate Inspection Numbers with 3 different inspectors from 2 different agencies.
They came to our facility because of a complaint. Since it was a complaint they could ONLY look at the issues brought up from the complaint and could not do a wall to wall inspection. During their investigation of the 5 points from the complaint if they saw anything that was egregious in nature the investigation could turn into a wall to wall inspection. We were fortunate that it did not turn into a wall to wall inspection but he did notice ink on our dumpster and referred an inspector from the DEQ to look into that.
3 of the 5 complaints were total BS and were not taken seriously by the inspector. The two he took seriously were the Machine Guarding and ventilation of chemicals. During our closing conference the inspector issued a Serious Violation and fine ($750) for the lack of Machine Guarding on our 3 automatics and gave us 60 days to remedy the situation. He also referred an Industrial Hygienist who works for MiOsha to look into the ventilation of our chemicals because he was not qualified.
The Industrial Hygienist came out and inspected our SDS sheets, eye wash, storage of chemicals, where we used the chemicals, labeling of secondary containers, our Hazard Communication Program, Respiratory Program, and watched how the chemicals were used. She ended up coming in a second time with a machine that we hooked to a couple of employees and monitored the air around them while working and using Press Wash, adhesives, ink, etc...
We passed the employee monitoring tests but our Hazard Communication Program, Eye Wash, Respiratory Program and labeling of secondary containers were not up to par. In all 4 situations we had something in place but did not have it completed to their standards. For example, our eye wash was just a standard bottle that you squeeze into your eye, they wanted an eye wash station that could supply 15 psig for 15 minutes. She issued minor violations for all those AND for not properly monitoring our Optilux Reflective Ink prior to putting it into production. While she was going through our SDS sheets she noticed the reflective ink and saw that it had Sodium Chloride (I think that is the chemical) in it. She asked if we have ever done air monitoring while an employee uses this ink and we never had. Since it had Sodium Chloride in the ink, to comply with their standards we needed to perform air monitoring while an employee prints with it before keeping it on our shelves and using it for production runs.
The fines levied by the Industrial Hygienist tallied up to $2100. I had no out for those fines so I called her boss the day we received the paperwork and agreed to an informal settlement and had the fines reduced to by 50%.
Back to the ink on the dumpster.... The DEQ inspector came and noticed the ink on the Dumpster, not a ton by any stretch of the imagination but there was some on the top edges of the dumpster. We also have a large floor drain inside of the shop that is covered by a manhole which has slits in it. He observed some packaging materials like popcorn and tape in the drain and asked us if it went to the storm drains or to the sewage drains. His concerns were that the ink on the dumpster and packaging materials were making there way into the storm drains and contaminating them.
This is the best part though, he was not going to fine us OR make us fix the issue we just had to pay $350 YEARLY for a license that basically allows us to do that. Even though I was frustrated and did not want to argue with the guy, I also did not want to piss away $350 per year. I asked him what we could do to avoid paying the yearly extortion (I mean license fee). He said basically nothing and to pay it. My first question was can we just get a solid manhole cover instead of one with slits in it? He said yes that is would be fine. Then I asked if we could get a brand new clean dumpster and alter the way we handle our ink waste and he also said that would be fine. As you can see he was very helpful...
I called Waste Management and I was very happy to hear that part of our contract we are eligible to receive a new dumpster once a year. So, I bought a new manhole cover for $165, ordered the new dumpster, took a few pics and emailed the DEQ inspector and we were all good to go.
Now back to the machine guarding, every inexpensive idea I threw at the inspector were shot down. He said the only thing that would work would be a laser curtain. I read up on my appeal options but did not want to because I thought it might open up a can of worms and he would come back pissed off and nit pick us to death. Finally, after investigating M&R's laser curtain and having a few machine guarding companies down to take a look and having them ALL tell us that this seems unreasonable I decided to call the inspectors boss.
My plan was to try and be a polite as possible, prod a little bit and see what his thoughts were about the situation. I wanted to ask if he had any ideas and to see if he thought I had any wiggle room on this. During the initial inspection the inspector took photos of the machines; that helped tremendously when I was talking to the Supervisor and explaining how the machines work. To my surprise before I could even get into that much he just said "Do not spend any more time or money on this, if I were you I would appeal". I was caught off guard and probably stuttered 10 times and could not get off the phone quick enough to file the appeal. So, I went down the appeal path and just today I received the letter saying the Violation and Fine were being excused. I was so relieved when I read that letter and my heart was pounding when I was opening it up.
I really learned a lot during the past 3.5 months and I am not happy to have to pay 1k in fines; however it is going to make us a better company and bottom line is we went half way on some items and did not follow the MiOsha standards 100%. I am just thankful that the machine guarding issues fell our way and crossing my fingers that we did not piss anyone off by appealing.
Well, thats my story and hopefully it is not too much rambling and makes sense since I typed this on a Friday night after a few beers.
If anyone has any issues comparable in the future feel free to contact me and I will help in any way I can.
Mark
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That's awsome, congratulations.
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Thanks. All that is great to know. That's cool things worked out for you.
Murphy37
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Great to hear Mark! Sounds like keeping your cool paid off!
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Congrats Mark. Sometimes all that's needed is to sit down with someone sane and say "um....really?".
I actually like inspections because it makes us safer. I don't like some of the nonsense behavior described in your posts, things like fining you because a scrap of tape was near a storm drain or because a little ink was on a dumpster, that's just silly. But I appreciate the opportunity to make the place safer, just like you do. Way to make lemonade there.
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They made us put guards at the back rollers of all the dryers. "Nip Points"
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WOW. This is such a valuable post that all future readers/shop owners can learn from. Good one. Very good.
Thanks for taking the time to share that with us.