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Re: Press Guarding exceptions
Submitted by Mark Wallace on 11/Oct/2007 in reply to Press Guarding exceptions posted by Dbowyer on 10/Oct/2007
Message:
You might be refering to directive CPL 02-01-025 'Guidelines for Point of Operation Guarding of Power Press Brakes'( http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1530 ). It says:
5. Because of constraints imposed by certain manufacturing or fabricating processes, safeguarding by maintaining a safe distance from the point of operation may be acceptable but only when safeguarding by physical barrier or physical devices is not feasible. "Safe distance" means the clearance between an employee (typically his or her fingers holding and supporting a piece part) and the power press brake point of operation.
6. Safeguarding by maintaining a "safe distance" is acceptable if:
a. The employer demonstrates that physical barriers and physical devices are not feasible to guard the power press brake point of operation. Physical devices typically include: two hand controls, holdouts or restraints and presence sensors.
b. The employer demonstrates that power press brake point of operation guarding by maintaining a safe distance is limited to one-time only fabrication of made-to-order or custom-made piece parts. Small quantity runs, typically performed in job shop or model shop establishments may be affected by this provision; high volume piece part rates of production will not. A "small quantity run" means fabrication of more than one of the same piece parts over a continuous timeframe of no more than four hours per month.
NOTE: Special feasibility guidelines for small quantity runs: When physical guards and physical devices are not feasible for small quantity runs as defined above, safeguarding by maintaining a safe distance as described in this directive is an alternative to power press brake replacement or major renovation which otherwise could provide employee protection.
c. The employer has a safety program which includes safe work procedures, training, and supervision to ensure that work is performed using "safe distance" alternative measures.
d. The employer has a workplace history of operating power press brakes safely by maintaining a safe distance from the point of operation. Such a history is characterized by absence of injuries related to failure to maintain a safe distance. Workplace history will be evaluated by Compliance Safety and Health Officer review of employer records and interviews or observations of employees.
I would imagine that you would have to build this into a formal safety program and be able to show that the operators receive adequate ongoing training.
It will be interesting to hear what others think.
Mark Wallace
Boise, ID
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