Tackling OSHA’s Top 10 Citations: 1910.212 - Machine Guarding

Video

Jill James

Jill James

Chief Safety Officer

Jill James brings an unrivaled perspective on risk, regulation and liability. With 14 years of experience as a Senior OSHA Safety Investigator with the State of Minnesota, and nearly a decade in the private sector as a safety program manager, Jill is a passionate advocate for training ROI.

The following is an excerpt from Tackle OSHA’s Top 10.

Hosted by Chief Safety Officer Jill James, you can listen to the webcast on demand.


So with regard to machine guarding, the video above that you're seeing is actually from a supervisor safety tip video that we have hosted on our websit in our toolbox area, where you can look for supervisor safety tips, and you can see a video of me explaining machine guarding, and how to identify those hazards.

This particular video is of me explaining what you want to look for with machine guarding. You're looking for hazards of rotating parts, in-running nip points, points of operation, and flying chips or sparks. To give an example, this video features an old labeling machine, in Cannery Row, in Monterey Bay, at the aquarium, where this video was shot.

In this video you'll see two drums. Those would be turning inward, and that would be the point of operation where the actual label was put on a device many years ago, in the cannery. That's called a point of operation. An employee could get pulled in. That needs to be guarded.

Then, another example, this would be called an in-running nip point. It wasn't actually where the work was taking place, but it was helping the machine operate. So those two rollers were turning inward, having the ability to pull someone in. In-running nip points need to be guarded, so be on the lookout when you're looking at machine guarding, for in-running nip points, points of operation.

Then, this was a pulley and belt drive. The pulley system itself can get people wound into it. Then there would be in-running nip points where the belt would have been turning on there, so that would be an additional hazard, that that would need guarding.

What we're seeing here is a former chain and sprocket, and you can see the guard where my right hand is placed. That is a guard, but it's not completely guarded, so when you're looking at guarding with machine guards, know that you can ask yourself this question, "Can I reach over, around, under, or through to that point of operation, to the in-running nip point, to the place where I could get wound in?" If the answer is, "Yes, I can reach over, around, under, or through," then you have an incomplete guarding situation that needs to be remediated.

So I mentioned flying chips and sparks earlier. This is a metalworking lathe, so the hazard with this is when the metal is being worked, then we have flying chips that can come out at the employee. They can be hot. They can get in their eye. They can go down their shirt, cause a burn. So, guarding with flying chips and sparks, in this case, would be that plexiglass shield that you see in the photo.

In the center of this picture, where the expanded metal is, that is a really nice guard that you cannot reach over, around, under, or through to the belt and pulley mechanism on the inside of that.

So is machine guarding required? Training, rather. No, it's not. Believe it or not, there's a lot written about how to protect people, but there isn't anything that says they need to be trained. Is that's something that you should be training on? You know, absolutely. It's a good practice. It's definitely a best practice, so employees at least know how to identify what those hazards are, and how to protect themselves, and that you can't be creating guards out of duct tape or cardboard.