Monthly Archives: November 2015

Machine Guarding

Effective machine guarding on stationary and portable equipment and tools is a vital aspect of workplace safety. In addition, proper instruction to employees on the necessity of machine guarding is another important aspect of an effective workplace safety program. Ensure that your employees know how to inspect and adjust machine guarding and when it is safe to do so.   Unfortunately, some business operators fail in delivering these key aspects of workplace safety and if and when OSHA discovers this fact, the fines can mount. But more than that, employer consideration should focus on the safety and welfare of their employees.

Lack of effective machine guarding is a common OSHA violation. Sometimes the workplace many have one or several pieces of vintage equipment that never had a machine guard in place to protect workers from moving parts. Commonly, they are large-scale metal working machines such as presses and sheers – usually recycled from other industries or even as military surplus. It does not matter how old the equipment is; you need to ensure that it has safeguards to protect employees from moving parts.  Jerry-rigged and unreliable attempts at machine guarding are just that. If your equipment lacks effective safeguards, either add reliable ones or take the equipment out of service. Add-on devices include dead man switches, safety interlocks, self-adjusting guards, fail-safe switches, tripwires, presence-sensing devices, restraints and so on.

While OSHA allows some operator adjustments to equipment while it is operating, purposely defeating safety interlocks, removing covers and/or access hatches and other means are prohibited. Unfortunately, we have seen cases where the employer removes and even hides machine guarding covers so their employees can reach into machinery while it is operating in order to keep an assembly line (for example) running. That’s not a good idea and an employee injury or fatality the result of lack of machine guarding will do more than shut down a process line; it may shut down the entire operation.

Portable equipment and tool machine guarding brings to mind tools used in the field by construction workers such as saws, grinders and the like. Here too, sometimes employees – with a tacit nod from their employer – remove guards so the equipment can be used basically outside of their proper scope operation. Removing guards in this way subjects the employee to injury. Ensure that your employees know how to inspect and adjust machine and tool guards and underscore the importance of keeping guards in place.

For more information, visit the US DOL OSHA web site:

Electrical Safety and the 2015 NFPA 70E Standard

In 2015, the NFPA made changes to wording and practices in their revision of the NFPA 70E Standard for electrical safety in the workplace. Of note is that when all was said and done, this guidance document identifies minimum acceptable safe work practices rather than best practices. However, workers can still take additional steps to protect themselves. The Standard clarifies “normal operation” of electrical equipment operating at 600 volts or more [Section 130.2 (A)(4)]. The updated Standard also adds clarifying language regarding the installation and upkeep of electrical equipment [Section 1304 Z(B)].  The 2015 edition of NFPA 70E hopefully removes confusion over their previous Prohibited Approach Boundary precautions [Section 130.4(b)] by instead focusing on the LAB (Limited Approach Boundary) and RAB (Restricted Approach Boundary) around potentially arc-flash-producing electrical equipment.  Additionally, the 2015 NFPA 70E reinforces the requirement to keep access to electrical equipment clear in all cases as does OSHA and various fire codes for prohibiting storage in the working space of electrical equipment (including breaker panels) even for temporary storage [130.6 (H)]. Finally, another important change is the 2015 70E’s revised arc flash PPE tables [Section 130.7 (c)(15)]. If your employees have high voltage exposures especially, refer to the NFPA 2015 70E Standard.

Multi-Employer Worksites

Federal OSHA requires primary contractors to ensure that their subcontractors also meet OSHA workplace safety requirements. However, here in Utah in 2014, the Utah Supreme Court rejected the Federal OSHA Multi-Employer Worksite Safety Doctrine. You should determine if similar legal findings have challenged multi-employer work sites in your location. According to an article in EHS Today, “The Court concluded that Utah employers are not responsible for the safety of their subcontractors… With the decision, the court rejected the federal labor law known as the multi-employer worksite doctrine. With the decision, the court rejected the federal labor law known as the multi-employer worksite doctrine, which holds a general contractor accountable for the safety of all employees on a worksite, including those of subcontractors. The court asserted that the federal doctrine is ‘incompatible with the governing Utah statute.’”

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EHS Management Systems

We have discussed the benefits of formalized EHS (environmental, health & safety) management systems previously. The prevailing environmental management system is the ISO 14001 EMS. The prevailing international occupational health and safety management system is the OHSAS 18001. There is also the OSHA Z10 which is recognized only in the USA. Any of these will work for you but it depends upon your needs. Often, the need for certifiable management systems comes at the urging if not request of your business partners. For example, if you are a supplier to an international company that already has ISO 14001 in place and/or OHSAS 18001, adopting these systems may be one of their requirements for doing business with them. The benefits of a formal EMS or occupational health and safety MS are many. A few include being more effective in your management of risk and regulatory requirements to achieving industry and consumer recognition for your methods.

Fear not, because despite the common apprehension of adopting a “new” way of managing your risks, most companies find that they are already doing probably 90 percent of what these formal management systems require. On short, they are time-tested, efficient and effective real-world applications that make sense to implement regardless your industry requirements.  Ask Safety and Environmental Help how we may assist with analysis of your needs and with preparing a formal management system for you.

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