case study 1 printing press roll cleaning

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Home > Learn Lockout Tagout > OSHA Case Study 1 – Printing Press Roll Cleaning

OSHA Case Study 1 - Printing Press Roll Cleaning

A printing press produces printed materials as its normal production function. The printing press's rollers have to be cleaned periodically during the work shift to ensure quality control. In this scenario, the press is not shut down for the cleaning operation. The printing press is Energized and its rollers continue to spin at a very high speed. In order for employees to clean the rollers they must bypass the printing press's machine guards, and use rags to clean the rollers. This exposes them to serious, ingoing nip point hazards created by the rollers. Severe laceration or amputated fingers could result if the rag or an employee's hand were to get caught in the rollers or in an area between the rollers and a fixed part of the machine. Although the employer has a Lockout/Tagout program for Servicing and/or Maintenance of the printing presses, for this particular cleaning operation the employer believes that Lockout/Tagout Procedures do not need to be implemented. According to the employer, this cleaning operation is exempt from Lockout/Tagout requirements because it falls under the minor servicing exemption and therefore the employer allows the equipment to remain operating during the cleaning operation. Remember, as stated above, the employees are still exposed to the Hazardous Energy of the printing press' during the cleaning operation.

Is this printing press roll cleaning activity covered by the Lockout/Tagout standard?

The employer argues that the roll cleaning activity is routine, repetitive, and integral to the production operation and that Lockout is not required because the minor Servicing exception described in 1910.147(a)(2)(ii) is applicable. Is the employer correct?

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Case Study 1: Printing Press Roll Cleaning

Incorrect.  In this case, the employer is not correct.

The minor servicing exception does not apply. Even though the roll cleaning activity takes place during normal production operations and is routine, repetitive, and integral to the production operation, the employer has not implemented alternative measures which provide effective protection from the ingoing nip points of the press rolls. Employees instead are required to bypass a machine guard, which is required by Subpart O of 29 CFR 1910 , and place their hands and cleaning rags into the press's danger zone. In the absence of alternative protective measures, this cleaning task is a servicing or maintenance activity that is covered by 1910.147 .

In summary, for the minor servicing exception to apply, each and every element of the exception must be met. In this case, the work is not being performed using alternative measures that provide effective employee protection.

For more information: Read the September 16, 1992, letter of interpretation to Mr. John Runyan of the Printing Industries of America, Inc., for details on how to use safe alternative measures for printing presses.

<< Return to Case Study Discussion | Next Case Study >>

OSHA Case Study – Lockout Tagout and the Minor Servicing Exemption

Sep 20, 2023 | Health and Safety , Newsletter

In this article, we are sharing an OSHA Case Study that explores the topics of lockout tagout, the minor servicing exemption, and machine guarding. Read on to test your understanding of when and how OSHA’s minor servicing exemption can be applied.

The Case Study:

A printing press produces printed materials as its normal production function. The printing press’s rollers have to be cleaned periodically during the work shift to ensure quality control.

In this scenario, the press is not shut down for the cleaning operation. The printing press is energized and its rollers continue to spin at a very high speed. In order for employees to clean the rollers, they must bypass the printing press’s machine guards, and use rags to clean the rollers. This exposes them to serious, ingoing nip point hazards created by the rollers. Severe laceration or amputated fingers could result if the rag or an employee’s hand were to get caught in the rollers or in an area between the rollers and a fixed part of the machine.

Although the employer has a lockout/tagout program for servicing and/or maintenance of the printing presses, for this particular cleaning operation the employer believes that lockout/tagout procedures do not need to be implemented. According to the employer, this cleaning operation is exempt from lockout/tagout requirements because it falls under the minor servicing exemption and therefore the employer allows the equipment to remain operating during the cleaning operation.

Remember, as stated above, the employees are still exposed to the hazardous energy of the printing press’ during the cleaning operation.

Is this printing press roll cleaning activity covered by the Lockout/Tagout standard? Yes or No?

If you said Yes:

You are correct. Even though this roll cleaning activity takes place during normal production operations, the employee is required to bypass a machine guard and/or place part of their body into a point of operation or associated danger zone. The cleaning operation is therefore covered as service and maintenance which took place during normal production operations. Therefore, the requirements of 29 CFR 1910.147 apply.

The employer argues that the roll cleaning activity is routine, repetitive, and integral to the production operation and that lockout is not required because the minor servicing exception described in 29 CFR 1910.147(a)(2)(ii) is applicable. Is the employer correct? Yes or No?

If you said No:

You are correct. The minor servicing exception does not apply. Even though the roll cleaning activity takes place during normal production operations and is routine, repetitive, and integral to the production operation, the employer has not implemented alternative measures which provide effective protection from the ingoing nip points of the press rolls. Employees instead are required to bypass a machine guard, which is required by Subpart O of 29 CFR 1910, and place their hands and cleaning rags into the press’s danger zone. In the absence of alternative protective measures, this cleaning task is a servicing or maintenance activity that is covered by 29 CFR 1910.147.

In summary, for the minor servicing exception to apply, each and every element of the exception must be met. In this case, the work is not being performed using alternative measures that provide effective employee protection.

In this case study, was your understanding of the standard challenged? Understanding and correctly applying OSHA standards to real, work place scenarios can be complicated. Many of OSHA’s regulations are interconnected, especially when it comes to Lockout Tagout, exemptions to Lockout Tagout, and thus, their reliance on adequate machine safeguarding methods.

Lockout Tagout exceptions (i.e., the minor servicing exception) can only be applied when the activity meets certain criteria first. An OSHA standard interpretation letter provides further explanation on when the exception can be applied:

The activity must take place during, and must be inherent to, normal production operations (which include the utilization of a machine or piece of equipment to perform its intended production function). These functions would be carried out by employees with the machine or equipment energized. They may include minor servicing activities (i.e., clearing of jams; minor cleaning or adjustments; lubrication) that safely take place while the process is performed in situations where extensive disassembly of the machinery/equipment is not required.

The activity must be:

1. Routine: The activity must be a regular course of procedure and be in accordance with established practices.

2. Repetitive: The activity must be repeated as part of the production process or cycle.

3. Integral: The activity must be inherent to the production process.

If all of these apply, then the employer can determine how to use alternative measures to provide effective protection from the hazardous energy. Alternative measures can include various applications of equipment safeguarding, as described in OSHA Subpart O: Machinery and Machine Guarding. Machine guarding can include fixed guarding, interlocks, and ensuring exclusive control by the person executing the exemption procedure.

Additionally, procedures for alternate measures should be developed and documented. The procedures must define how and when the exception will be applied and executed. Following development, employees who will use the procedure must be trained in them to ensure proper understanding and use.

CMI has a team of Health and Safety experts that can work with your team to develop equipment-specific Lockout Tagout Procedures, assess where minor servicing exceptions can be applied to your operations, and develop standard operating procedures for minor servicing activities. Our team can also evaluate equipment to determine where adequate machine safe guarding is in place and identify areas that may need improvement. We routinely conduct various trainings to ensure employers are in compliance with the control of hazardous energy standard, including Lockout Tagout for Affected employees, Lockout Tagout for Authorized employees, and hands-on periodic inspections for the execution of Lockout Tagout Procedures.

Written by Rebecca Caffrey, CSP

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PREPAC® Advanced Cleaning Rolls For Sheetfed Offset Printing At Duma Druck

Outstanding cleaning features are keys to optimized productivity: Learn how German printer Duma Druck discovered this, saving time and production costs by using Baldwin’s PREPAC Advanced roll cleaning-cloth solution.

Customer: Duma Druck, established 1983 is situated in Wolfsschlugen, close to Stuttgart, Germany, is a commerial offset and digital printer well known for a consistent quality management. Challenge: Reduce the waste of paper, time and production costs. Solution: Baldwin PREPAC® Advanced cleaning rolls. Benefits: No more fluff on the impression cylinder, no dripping or toning, easy handling and increased production uptime thanks to enhanced cleaning efficiency leading to shorter wash times.

Read the full case study now - click the image below to access the full PDF:

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A method of minimising paper requirements for offset printing

The conducted study desired to increase the accuracy of estimating paper quantity requirements for printing. Changes in press construction and auxiliary equipment help reduce the total waste during production; however, typical estimation methods do not take these changes into account. By specifying the number of important job parameters and using a dimensional analysis approach, it was possible to devise a model of waste sheet quantity estimation better suited for current production practices. Using this model, it is possible to reduce the quantity of paper required for a particular print run as well as better predict the total waste sheet quantity. As a result, less paper may be ordered, stocked, and utilised in production. Using this model, a printing house may develop unique technological allowance standards for their particular substrates and products. The method of waste quantity prediction presented in this paper is also suitable for establishing a quality control system.

Full Article

A Method of Minimising Paper Requirements for Offset Printing

Jacek Hamerlinski  a, * and Yuriy Pyr’yev  b

Keywords: Offset printing; Paper requirements; Paper waste; Dimensional analysis

Contact information: a: Research & Development Centre for the Graphic Arts, Miedziana 11, 00-958 Warsaw, Poland; b: Institute of Mechanics and Graphic Arts, Faculty of Production Engineering, Warsaw University of Technology, Konwiktorska 2, 00-217 Warsaw, Poland;

* Corresponding author: [email protected]

INTRODUCTION

In sheetfed offset printing, paper is always wasted in press setup and production errors (rejection  via quality control procedures). In addition, the finishing processes require an additional allowance (this quantity is not affected by the printing process and is not covered in this paper). This means that during the printing process for a particular job, additional paper should be provided to account for “unsalable” production (Kipphan 2001). The additional paper provided is subsequently the technological allowance required to produce the final product. The additional quantity is calculated with respect to run length ( i.e. , the required number of final products) and printing process characteristics ( e.g. , type of press, number of colours). Formulae for such calculations are relatively simple and use statistical data from various sources, typically within one country (BPIF 2012; COBRPP 1986; Samarin 2002). Currently, there is widespread use of multi-colour presses, which use various automation systems (DeJidas and Destree 2005; Kipphan 2001) designed to shorten the makeready (press setup) time and reduce overall waste (Kipphan 2001). The industry-standard formulae have been found to be too pessimistic. For example, BPIF 2012 assumes that 500 waste sheets are required for each setup in four-colour printing. For that reason, paper quantity requirements have been calculated at a more drastic level than necessary. As the paper returns from production, sometimes it cannot be reused, and the surplus quantity drains both natural resources and company cash.

It must also be noted that waste paper (and any paper no longer suitable for printing after storage) must be processed, which consumes a varying amount of additional resources depending on the method selected (Hubbe 2007; 2014). Devising a method to limit the unnecessary allowance would make printing plants more sustainable. This particular study analyses the potential dependencies of paper waste on different factors, including printing process variables and the job data. The novel approach presented here may be useful as a starting point for creating company-specific models of estimating paper quantity for sheetfed offset printing process.

Estimating Paper Waste in Offset Printing

Basic estimation of paper waste in the sheetfed printing process is calculated using the following equation (Samarin 2002),

where  n w  is the estimated number of waste (unsalable) sheets,  k  is the number of job colours (4 in the case of CMYK offset printing),  n  is the required quantity of printed sheets,  N m  is the waste sheet quantity required for makeready, and  p p  is the percentage of waste expected during the press run.

The values of  N m  and  p p  can differ depending upon the press type and configuration, paper type, quality requirements, and quantity range (Samarin 2002). In some cases, the outcome is multiplied by specific correction factors that depend on paper weight (grammage), sheet size, press equipment,  etc. (COBRPP 1986). If a press run requires front and back printing, the method of predicting the waste quantity depends on the selected method of second side printing, number of plate sets required, or using a press equipped for single-pass double-sided printing (COBRPP 1986). Similarly, when the quantity required exceeds the durability of the offset plates used for printing, more makeready waste sheets must be provided (COBRPP 1986). The values for  N m  and  p p  are tabularised for convenience. To find an appropriate value, one must know which press will be used for printing the specified job, as well as what other conditions (such as the quality requirements) will apply.

The offset printing process is generally stable if set up properly (Kipphan 2001) and in a typical printing environment, one may assume that the press setup is the largest source of waste sheets during any print run. Notably, the predicted waste sheet quantity is directly proportional to the number of printed colours, meaning that setting up a four-colour (CMYK) job will generate significantly less waste than setting up a job including additional spot colours.

This correlation leads to overestimation of the waste quantity for many presses with five or more printing units, especially when such presses include automated functions such as plate changing, blanket washing, or pre-inking. These features not only shorten the makeready time (Kipphan 2001), but also reduce the number of waste sheets produced thanks to faster, more precise, and more repeatable performance of standard tasks. Because the cost of printing is the largest contributor to total production costs (DeJidas and Destree 2005), changes in this area can significantly affect the financial standing of the company.

EXPERIMENTAL

Theoretical Problem Analysis

A study undertaken in the Research and Development Centre for the Graphic Arts (COBRPP) was aimed at reviewing the current standards of computing the technological allowances for sheetfed offset printing in correlation to the actual numbers of waste sheets registered in commercial print runs. During this study, it was found that the estimation of waste sheets was generally too high and that the same quantity of waste was predicted for a wide variation of press runs. Therefore, a different approach for predicting the waste sheet quantity has been developed. The new method of predicting the waste sheet quantity can make waste estimates more realistic, inherently lowering the demand for natural resources. Such an approach was based on the notion that there are several common factors affecting the printing process, and it should be possible to find a relationship between appropriate similarity numbers using dimensional analysis.

A number of parameters describing a given print run were analysed. The parameters selected should be known at the moment of estimation and/or registered during the print run. The parameters taken into account are set forth in Table 1, where M is mass, L is length, and T is time.

Table 1.  A List of Parameters for Estimating Waste Sheet Quantity

With the exception of ink tack, all of the aforementioned parameters are regularly used in ordering and job description or costing. The ink tack, or a force required to split ink layers ( e.g.  between the inking rollers), is an important parameter of the offset printing process, influencing many of the effects observed in printing (Gujjari  et al . 2006; Mangin and Silvy 1997; Mattila and Passoja 2006; Vähä-Nissi  et al . 2010). Ink tack is measured using different methods (Hamerlinski and Pyr’yev 2013; ISO 12634 1996), and these methods establish many different units of ink tack. As a result, the ink tack values quoted in different papers are not directly comparable (Massolt 2003), but instead are consistent for any measurement method and may also be verified in-house. The physical dimension of ink tack results from its understanding as the ink-splitting work required per area unit (Shakhgeldyan and Zagarinskaya 1975).

Furthermore, it is important to note that all the parameters may have only positive values. Because ISO 12647-2 describes several types of paper used for printing, such as 5 or even 8 (ISO 12647-2 2004; 12647-2 2013), it was decided that the function should also be different for each paper type. This study concentrated on the three types of paper most widely used in sheetfed offset printing,  i.e. , uncoated paper (equivalent to ISO type 4 in ISO 12647-2), coated paper (equivalent to ISO types 1 and 2), and cardboard. It also assumed that the required print quality is an average standard, with no exceptionally high or low deviations. Therefore the quality level was not considered a factor in the model. However, adding a scaling coefficient based on expected quality should be sufficient in practical cases.

Theoretical Formula Approach

Having established the set of characteristic parameters, dimensional analysis was used to formulate a relationship between the parameters and the number of waste sheets for a given print run, in the form of,

where δ is the waste sheet coefficient (dimensionless) expressed as a ratio of waste sheet quantity to the number of copies printed, and  p i  is a characteristic parameter of job or printing process.

Assuming that the function is a product of power monomials, it may be expressed as,

where C 1 , A, B, …, J are constants. Using dimensional analysis leads to the theoretical formula:

Data obtained from actual press runs (using presses with 4, 5, and 6 units) in Polish printing houses were then used to calculate the values of the constants. The formula may be rewritten as

RESULTS AND DISCUSSION

Based on 120 collected commercial job data printed with sheetfed offset presses, the multidimensional linear regression was applied for a subset of jobs printed on a particular type of paper, allowing to calculate the values of constant C 1  and exponents A, B, C, E, H, and I for each paper type separately. It was discovered with the help of  t -statistics that some parameters specified in Table 1 are statistically irrelevant for certain paper types; in such case a new model, omitting the irrelevant parameter, was analyzed. The model was considered correct only when all  t -statistics exceeded critical values and the coefficient of determination was higher than 0.8 for the analytical formula. As a result, the models for the different paper types are inherently different, as shown in Table 2. The regression analysis resulted in a quite simple model for cardboard printing.

Table 2.  Formulae for Estimating Waste Sheet Quantity for Different Paper Types

The estimated number of waste sheets may easily be derived from these equations by recognising that  n w  =  δn . Essentially, the relationship between  n w  and  δ  entails that by adding 1 to the exponent of  n  in the equation from Table 2, one can obtain the formula for the waste sheet quantity.

The verification consisted of comparing the actual waste sheet quantity with the theoretical quantity computed using the appropriate formula for each case used in the linear regression model. The Root Mean Square (RMS) deviation of theoretical values from the actual figure is shown in Table 2 as a percentage of actual values.

Interestingly enough, regarding cardboard, the number of colours printed has no influence on the estimated quantity of waste sheets. For all types of paper, the exponents for quantity and number of colours vary drastically, suggesting that the number of waste sheets is in fact not directly proportional to the number of colours printed. The R 2  values indicate that these models are efficient enough to be used in industrial practice, a claim further supported by the values of the deviation of the root mean square from the actual print run data. The highest accuracy for the model was observed when studying coated paper.

Finally, to verify the model, the formulae have been used to calculate the expected waste quantity for some print runs not used in the linear regression. In comparison to standard waste sheet estimating methods (COBRPP 1986; Samarin 2002), it was found that the new model minimises the quantity of paper required for printing. In most of the comparative cases (taken from the number of experiments not used for linear regression analysis) depicted in Fig. 1, the quantity of waste sheets estimated using the new model was the most accurate in predicting the actual waste sheet quantity registered during the print run. Additionally, the waste sheet figures produced by the new model were consistently lower than any of the other models tested. The new model also properly predicted an unusually high quantity of waste associated with printing on cardboard (case 6), whereas the other methods produced results much lower than the actual value (Fig. 1). In case 5, the estimated waste sheet quantity was higher than not only the actual value, but also the quantity estimated by other methods (Fig. 1). However, that particular case used UV varnishing, which could have affected the credibility of the averaging of the ink consumption and ink tack required for calculation, according to the developed model. Nevertheless the model is suitably close to the experimental data even it such a case.

Table 3.  A List of Parameters for Test Print Runs

The result of the comparison is shown in Fig. 1. This radar plot shows an actual quantity of waste sheets compared with three methods of estimating the waste quantity, “Theoretical” corresponding to the model discussed in this paper. It may be observed that it matches the actual figures better than the other two models.

Fig. 1.  A comparison of different standards of waste sheet calculations  vs . actual values from a sample of eight print runs in Poland

CONCLUSIONS

• Using the discussed method of estimating waste sheet quantity for a given sheetfed offset print run, it is possible to limit the quantity of paper for production, saving capital outlay and reducing environmental impact. The method is particularly suited for multi-colour sheetfed offset printing and is feasible for both short and long print runs. Its practical application will depend on the number of available data for analysis, and on the verification of basic assumptions regarding quality, work practices etc.
• The presented model is adaptable to the particular conditions of any printing house, by allowing an analysis of data gathered from the production runs for more precise estimation of the waste quantity in subsequent jobs. The results may be periodically reviewed to reflect changes in equipment, quality requirements, operators’ experience,  etc.  Most spreadsheets used for reporting and analysing various aspects of production management are capable of performing the calculations required for this model.
• The method is also suitable as an input for statistical quality control (SQC) and the various indicators used in “lean” production management systems.

REFERENCES CITED

BPIF Standard Document (2012).  Allowances for Overs/Unders and Wastage , British Printing Industries Federation, Coventry, UK.

COBRPP (1986). “Materialy Pomocnicze do Opracowania/Weryfikacji Zakładowych Normatywow Zuzycia i Norm Ubytkow Oraz Systemu Rozliczen Materialow Poligraficznych (Supporting Information for Setting Up and Verifying Technical Allowances, Waste Sheets and Substrate Accounting System),” Branzowy Osrodek Normalizacji, Branzowy Osrodek Informacji Naukowej, Technicznej i Ekonomicznej, Warsaw, Poland.

DeJidas, L.P., and Destree, T. (2005).  Sheetfed Offset Press Operating , GATF Press, Sewickley, PA.

Gujjari, C., Batchelor, W., Sudarno, A., and Banham, P. (2006). “Estimation of ink tack in offset printing and its relationship to linting in offset printing,”  Proceedings of TAPPI International Printing and Graphic Arts Conference .

Hamerlinski, J., and Pyr’yev, Y. (2013). “Modelling of ink tack property in offset printing,”  Acta Poligraphica  1(1), 31-40.

Hubbe, M.A. (2007). “Incinerate, recycle, or reuse?,”  BioResources  2(1), 1-2.

Hubbe, M.A. (2014). “Recycling paper recycling,”  BioResources  9(2), 1828-1829.

ISO 12634 (1996). “Graphic technology – Determination of tack of paste inks and vehicles by a rotary tackmeter,”  International Standards Organization , Geneva, Switzerland.

ISO 12647-2 (2004). “Graphic technology – Process control for the production of halftone colour separations, proof and production prints – Part 2: Offset lithographic process,”  International Standards Organization , Geneva, Switzerland.

ISO 12647-2 (2013). “Graphic technology – Process control for the production of halftone colour separations, proof and production prints – Part 2: Offset lithographic process,”  International Standards Organization , Geneva, Switzerland.

Kipphan, H. (2001).  Handbook of Print Media , Springer Verlag, Heidelberg/Berlin.

Mangin, P.J., and Silvy, J. (1997). “Fundamental studies of linting: Understanding ink-press-paper interactions non-linearity,”  TAGA Proceedings, Technical Association of the Graphic Arts , p. 884.

Massolt, P. (2003).  Keep Your Tack on Track , VIP Publications, Testprint, Cherry Hill, NJ.

Mattila, U., and Passoja, S. (2006). “Factors controlling adhesion and ink tack in HSWO (Heatset web offset),”  Proceedings of International TAPPI Printing and Graphic Arts Conference .

Samarin, Y. (2002).  Normativy Razkhodovanya Osnovnykh Poligraficheskikh Materialov (Standards for Production Usage of Graphic Arts Materials),  Moscow State Print University, Moscow.

Shakhgeldyan, B. N., and Zagarinskaya, L. A. (1975).  Poligraficheskiye Materyaly (Graphic Arts Materials) , Izdatelstvo Kniga, Moscow.

Vähä-Nissi, M., Kela, L., Kulachenko, A., Puukko, P., and Kariniemi, M. (2010). “Effect of printing parameters on delamination of board in sheet fed offset printing,”  Appita Journal  63(4), 315-322.

Article submitted: April 8, 2014; Peer review completed: May 7, 2014; Revised version received: July 1, 2014; Accepted: July 2, 2014; Published: July 14, 2014.

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Home  »  Lockout Resources  »  OSHA Documentation  »  Interactive Case Studies  »  Printing Press Roll Cleaning

Printing Press Roll Cleaning

A printing press produces printed materials as its normal production function. The printing press's rollers have to be cleaned periodically during the work shift to ensure quality control.

In this scenario, the press is not shut down for the cleaning operation. The printing press is Energized and its rollers continue to spin at a very high speed. In order for employees to clean the rollers they must bypass the printing press's machine guards, and use rags to clean the rollers. This exposes them to serious, ingoing nip point hazards created by the rollers. Severe laceration or amputated fingers could result if the rag or an employee's hand were to get caught in the rollers or in an area between the rollers and a fixed part of the machine.

Although the employer has a Lockout/Tagout program for Servicing and/or Maintenance of the printing presses, for this particular cleaning operation the employer believes that Lockout / Tagout Procedures do not need to be implemented. According to the employer, this cleaning operation is exempt from Lockout/Tagout requirements because it falls under the minor servicing exemption and therefore the employer allows the equipment to remain operating during the cleaning operation.

Remember, as stated above, the employees are still exposed to the Hazardous Energy of the printing press' during the cleaning operation.

Is this printing press roll cleaning activity covered by the Lockout/Tagout standard?

Even though this roll cleaning activity takes place during normal production operations, the employee is required to bypass a machine guard and /or place part of his/her body into a point of operation or associated danger zone. The cleaning operation is therefore covered as service and Maintenance which took place during normal production operations. Therefore, the requirements of 1910.147 apply.

For more information: Refer to Lockout/Tagout standard parts 1910.147(a)(2)(ii), (a)(2)(ii)(A), and (a)(2)(ii)(B).

Incorrect. Actually, the activity is covered by the Lockout/Tagout standard.

Even though this roll cleaning activity takes place during normal production operations, the employee is required to bypass a machine guard and/or place part of his/her body into a point of operation or associated danger zone. The cleaning operation is therefore covered as service and Maintenance which took place during normal production operations. Therefore, the requirements of 1910.147 apply.

The employer argues that the roll cleaning activity is routine, repetitive, and integral to the production operation and that Lockout is not required because the minor Servicing exception described in 1910.147(a)(2)(ii) is applicable. Is the employer correct?

Incorrect. In this case, the employer is not correct.

The minor Servicing exception does not apply. Even though the roll cleaning activity takes place during normal production operations and is routine, repetitive, and integral to the production operation, the employer has not implemented alternative measures which provide effective protection from the ingoing nip points of the press rolls. Employees instead are required to bypass a machine guard, which is required by Subpart O of 29 CFR 1910, and place their hands and cleaning rags into the press's danger zone. In the absence of alternative protective measures, this cleaning task is a servicing or Maintenance activity that is covered by 1910.147.

In summary, for the minor Servicing exception to apply, each and every element of the exception must be met. In this case, the work is not being performed using alternative measures that provide effective employee protection.

For more information: Read the September 16, 1992, letter of interpretation to Mr. John Runyan of the Printing Industries of America, Inc., for details on how to use safe alternative measures for printing presses.

Source: www.osha.gov

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Physical Principles of Ultrasonic Technology

• © 1973
• L. D. Rozenberg 0

Acoustics Institute, Academy of Sciences of the USSR, Moscow, USSR

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Part of the book series: Ultrasonic Technology (ULTE, volume 1)

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Ultrasonic Devices for Intensifying Technological Processes

The Basics of Ultrasound Physics

Physical Principles of Ultrasound

Table of contents (24 chapters), front matter, ultrasonic cutting, introduction.

L. D. Rozenberg

Investigation of the Ultrasonic Cutting Mechanism

Disintegration of the material in ultrasonic machining, forces acting in ultrasonic cutting, effect of abrasive breakdown and renewal on the variation of machining speed, methods for enhancing machining performance; recent machine tool developments, ultrasonic welding of metals, basic information on the ultrasonic welding of metals, physics of the ultrasonic welding process, technological aspects and equipment requirements of ultrasonic welding, industrial applications, ultrasonic cleaning, the ultrasonic cleaning mechanism, efficiency of ultrasonic cleaning, cavitation—abrasion erosion, vibratory systems and equipment for ultrasonic cleaning, editors and affiliations, bibliographic information.

Book Title : Physical Principles of Ultrasonic Technology

Editors : L. D. Rozenberg

Series Title : Ultrasonic Technology

DOI : https://doi.org/10.1007/978-1-4684-8217-1

Publisher : Springer New York, NY

eBook Packages : Springer Book Archive

Copyright Information : Springer Science+Business Media New York 1973

Softcover ISBN : 978-1-4684-8219-5 Published: 20 September 2012

eBook ISBN : 978-1-4684-8217-1 Published: 11 December 2013

Edition Number : 1

Number of Pages : XXIII, 515

Number of Illustrations : 198 b/w illustrations

Topics : Electrical Engineering

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• Lockout-Tagout : Case Studies - Case Study 6: Steel Mill Teeming Car Repairs

Lockout/Tagout eTool

Case studies  » case study 6: steel mill teeming car repairs.

An employee is assigned to adjust part of the drive mechanism on a teeming car in a steel mill. The teeming car is isolated from its energy sources and locked out, and the employee crawls underneath the car to start the maintenance job.

The employee, however, fails to shut down or deenergize a separate motor-driven unit used to position the teeming cars. While the employee is performing the maintenance, the motor-driven unit is activated for production purposes and rolls by on adjacent tracks, causing injury to the employee.

Is the employer required to shut down and lock out related machinery operating in the area of the covered service and maintenance, if that machinery could cause injury?

Correct. The employer is obligated to provide the servicing and maintenance employee with protection against hazardous energy from interconnected and nearby machines or equipment which could cause injury. In this case, the energy control procedures were implemented for the teeming car. The employer failed, however, to lock out interconnected and nearby machines or equipment which exposed the maintenance worker to hazardous energy. The employer could either provide effective machine guarding or ensure that the energy control procedure for the teeming car requires the authorized employee to implement the energy control procedures for the motor-driven unit and for other interconnected or nearby equipment or machines. If the employer were to install guarding, it must protect the authorized employee from the hazardous energy of the interconnected or nearby machinery. If the guarding does not adequately protect the authorized employee during this servicing and maintenance activity, the interconnected and nearby machines or equipment must be deenergized and locked out/tagged out. In this case study, because guarding had not been installed, the employer was obligated to implement energy control procedures for the interconnected or nearby machines. The employer therefore failed to implement procedures to shut down, isolate, block, and secure machines or equipment to control hazardous energy (described in 29 CFR 1910.147(c)(4)(ii)(B) ). NOTE: This analysis could be readily applied to a scenario where maintenance must be performed on a punch press in an area crowded with other presses or energized equipment.

Incorrect. In this scenario, this step must be taken. The employer is obligated to provide the servicing and maintenance employee with protection against hazardous energy from interconnected and nearby machines or equipment which could cause injury. In this case, the energy control procedures were implemented for the teeming car. The employer failed, however, to lock out interconnected and nearby machines or equipment which exposed the maintenance worker to hazardous energy. The employer could either provide effective machine guarding or ensure that the energy control procedure for the teeming car requires the authorized employee to implement the energy control procedures for the motor-driven unit and for other interconnected or nearby equipment or machines. If the employer were to install guarding, it must protect the authorized employee from the hazardous energy of the interconnected or nearby machinery. If the guarding does not adequately protect the authorized employee during this servicing and maintenance activity, the interconnected and nearby machines or equipment must be deenergized and locked out/tagged out. In this case study, because guarding had not been installed, the employer was obligated to implement energy control procedures for the interconnected or nearby machines. The employer therefore failed to implement procedures to shut down, isolate, block, and secure machines or equipment to control hazardous energy (described in 29 CFR 1910.147(c)(4)(ii)(B) ). NOTE: This analysis could be readily applied to a scenario where maintenance must be performed on a punch press in an area crowded with other presses or energized equipment.

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