Regulatory agency standards and recommended industry practices

There are a number of regulations that pertain to controlling worker access to moving parts of production equipment and the management of exposure to mechanical energy. The Code of Federal Regulations (CFR) contains a number of minimum safety and health standards and best practices that pertain to mechanical energy and overall employee safety and prevention of injuries. Many are contained in 29 CFR 1900–1910.999 (OSH Act), which are summarized in Table 5.2. Some states operate state OSHA programs, and their regulations may be more stringent than the federal OSHA regulations. Readers should refer to the pertinent state OSHA websites for further information.

Designing process and production methods to eliminate hazardous conditions is one of the best ways to prevent accidents. When these conditions cannot be eliminated by design or engineering or substitution, then machine guarding and other controls should be considered. Regulations are intended to address proper controls should the design, engineering, and substitution options not be feasible or possible.

Two standards of particular importance are the OSHA machine guarding standard (29 CFR 1910.211—Subpart O) and the OSHA lockout/tagout standard (29 CFR 1910.147—The Control of Hazardous Energy Lockout/Tagout).

These two standards outline the requirements for (i) guarding or controlling access to moving machine parts and (ii) the elimination or management of energy that can power machinery or exist within the equipment when primary sources of power are disconnected or interrupted. These regulations are excellent tools for managing mechanical energy and will be reviewed in some detail in the section on Prevention later in this chapter.

Injury surveillance programs

Recognition and assessment of mechanical energy hazards are the first steps in successful management. Unfortunately, the first recognition of hazards is often realized after an injury, interruption of production, or an alarming “near miss.” Reactive assessments and incident investigations are an important part of identifying, measuring, and improving. However, using these assessments or investigations as the primary methods to identify mechanical energy hazards is an ineffective and costly practice.

A basic review of injury and illness experience is the first step. In the United States four readily available sources of information are (i) the OSHA 300 Log, (ii) the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A), (iii) the OSHA 301 or equivalent accident/injury investigation reports, and (iv) workers’ compensation claim data.

These data will highlight your past experience, some of the causes associated with your experience and costs and your actions to prevent injuries and illnesses. After a thorough review of your loss experience, a series of inspections of production areas is highly recommended.

OSHA regulations require an employer with more than 10 employees (at any time during the calendar year immediately preceding the current calendar year) to keep and actively manage an OSHA 300 Log (Figure 5.1). Some industries are partially exempt from the recordkeeping requirement based on the industry classification (see https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html). All employers, including those partially exempted by reason of company size or industry classification, must report any workplace incident that results in a fatality within 8 hours to OSHA. In-patient hospitalization, amputation, or loss of an eye within 24 hours of the event. Inpatient hospitalizations of three or more employees must be reported to OSHA within 8 hours.

Each OSHA recordable injury and illness must be recorded on the log within six working days of notification of the incident. A good-faith effort is required to maintain and update pertinent OSHA 300 Log information. Injury and illness recording requirements are contained in OSHA 29 CFR Part 1904—Recording and Reporting Occupational Injuries, and additional guidance is available online.² You may also contact your local OSHA consultation office for additional information and can contact Federal OSHA to request copies of any letters of interpretation on questions submitted by industry or formally request them under the Freedom of Information Act. States with state OSHA programs may also have additional recording and reporting requirements.

Five years of updated OSHA logs must be readily available, so these documents are a good historical record of your health and safety performance. Keeping the OSHA log information up to date, especially after the change of a calendar year, is often a challenge but is required to meet regulatory requirements. A listing of commonly used safety statistics based on the OSHA 300 Log is included in Table 5.3.

Lost workday case

An employee work-related injury or illness that is so severe that a worker is unable to come to work

Restricted activity case

An employee injury or illness that is severe; a worker, although able to come to work, is unable to perform all his/her regular job duties

Medical treatment cases

Employee injuries and illnesses that result in a worker being able to work; however, due to his/her work-related injury, treatment by a medical professional is required (i.e., stitches, prescriptions). The worker is able to return to full duties after treatment

Total employee hours worked

Represents the total hours worked (exposure to workplace hazards) by an employee population represented in the calculation. Note: 200 000 hours represents 100 employees working 2000 hours over a 1-year period. The rates can be reported as lost workday = restricted activity days per 100 employees or per hours worked

OSHA lost workday case rate

OSHA recordable rate

Another source of information are the OSHA 301s and accident and injury investigation reports. These reports will give you valuable information, including data on the number and types of injuries resulting in employees being unable to work (lost time), restricted in their regular work activity (unable to perform all their normal duties), and injuries requiring medical treatment by a qualified provider. Severity information on injuries and illness based on the days lost/restricted activity will also be included.

Your accident investigation reports of employee injuries and noninjury accidents including property damage, equipment damage, and, if available, near-miss incidents will help identify high-hazard work areas, tasks, equipment, and overall accident/injury trends. Once trends have been identified, plans can be developed to address improvements.

An OSHA 301 document (Figure 5.2) or its equivalent (your accident/injury investigation report) is also required for each entry on the log. You can design your company incident investigation form to meet the OSHA 301 requirements.

Your insurance carrier/broker can provide you with the third recommended source of information, your workers’ compensation (WC) loss/claim data. These data will provide general information on types of incidents, causes, body part injured, and costs incurred due to each reported WC claim. (Note: A number of state regulations may have a significant impact on the recording and reporting of WC claims. In addition, the recording and reporting requirements for OSHA log maintenance and WC claims are different. Some injuries may be recorded and reported in one system but not the other (i.e., OSHA recordkeeping requirements will capture restricted data activity cases, while workers’ compensation will not).)

WC costs can have a “long tail,” meaning that it often takes 5–8 years before they are fully realized. Thus costs reported at the close of a fiscal year will significantly increase over a 5-year period. As a general rule, your compensation costs at the close of a year will easily double within this 5-year period. Your insurance carrier may have loss control services, and their professionals can assist you in the prevention, management, and reporting of injuries and illnesses.

You may also use your WC experience modification rate (EX Mod) as an overall and general performance indicator. The EX Mod is based on a standard formula, and, with industry data, it considers but is not limited to your payroll, industry performance, and company WC performance for three previous and complete years (prior to your last year’s experience). A modifier can be compared between companies. An Ex Mod of 1 means that your costs and experience are average for your industry/competitors. A rate below 1 means that your performance is better than your competitors’/industry average and your costs are lower. This would be a competitive advantage. If your rate is greater than 1, your costs are higher and you are paying more than your competitors. With 3 years of experience considered, 1 poor year will impact your costs for up to 3 years.

After a thorough review of your claim data, a walk/inspection of the active production areas, offices, and especially the areas with serious or frequent incidents is recommended. These real-time observations of employee work practices, production processes, and equipment operation will complement your experience review. Conducting this walk with a knowledgeable and experienced safety professional and production manager or foreman is highly recommended. Their observations and answers to your questions on production processes and safe work methods will be invaluable.

Observations should be focused on the immediate work of employees and include the workers’ 360° environment. For instance, observe the activity and interaction of the employees in their workspace, with their equipment, materials, and equipment around them, to each side, overhead, underfoot, and behind.

Count the work actions involved in lifting, using tools, moving materials, and operating equipment. This will help you identify some sources of mechanical energy and the exposure potential. Your partner on the walk can assist you in identifying the work practices that are not consistent with safety requirements. Also count the pieces of powered equipment used in the areas you review. The more equipment and materials, the higher the potential for injuries.

These simple methods will help highlight the dynamics of your workplace, identify some of the sources of mechanical energy, and assist you in identifying a need for further assessment. Positive results from any of these basic injury surveillance program components suggest the need for further investigation and are summarized in Table 5.4.

Based on this initial assessment, a determination can be made of the need for further evaluation. Poor accident experience combined with an active production area, frequent employee equipment, and material interactions and high numbers of items of powered equipment indicate a greater exposure to mechanical energy and the potential for injury.

Safety surveillance

An effort to identify the need for an energy management system entails a comprehensive review, which is best achieved with a team approach. Experienced and knowledgeable personnel are required to identify equipment and sources of mechanical energy. The team should consist of members from production management: foreman, experienced workers, safety and industrial hygiene professionals, maintenance and plant engineers, and, where appropriate, equipment manufacturers.

Select a team leader (preferably an operations manager/director), keep the number of members to a minimum, and assign individuals specific project tasks. Using project management techniques, milestones, and timelines will keep the process on schedule. If there are other plants with the same equipment, divide the tasks among plants.

Table 5.5 contains the key elements for conducting a more detailed assessment. This list should be used as a reference and sections used only as appropriate. It is not all encompassing or complete; however, by researching your workplace needs and using parts of this list and adding others, you will customize the criteria for assessment. The assessments will identify the needs. Choosing corrective action and a long-term plan to implement and maintain a system will require the same team effort, commitment, and participation needed for the assessment.

The systems approach

Prevention of injuries and accidents utilizes various levels of safeguards to shield workers from hazards. The systems approach is a modern safety technique. In brief terms, it looks at the total system—people, materials, facilities, equipment, procedures, and process—to determine what could go wrong and in what way, what could cause it to go wrong, and what to do to keep it from going wrong. The approach should be and has been applied proactively from the design phase through the life of the system.

Systems are comprehensive and interrelated activities which, when acted upon in a consistent sequence, serve to complement each other to achieve continuous improvement. There are a number of approaches to developing a safety system, and the hallmarks include, but are not limited to:

1. Leadership—Management plays an active and visible role in establishing a team approach to developing, implementing, and maintaining continuous measurable improvement.
2. Self-assessment and performance management—Comprehensive self-assessments identify risks and liabilities and opportunities to manage these risks and limit potential losses. Metrics are established to accurately measure and report performance with the goal of continuous measurable improvement.
3. Personnel development—Organizational needs are identified and personnel selected to match both immediate and future needs. Personnel are developed to grow and change with the needs of the organization and business climate and as opportunities develop.
4. Design and operational integrity—Production and operational standards are identified, and immediate and long-range design, implementation, and operational standards are implemented.
5. Planning and change management—Strategic plans are developed to meet organizational and operational needs and ensure high-caliber performance in a competitive business environment. Change is an anticipated and integral part of the planning process. Contingencies are designed and readily implemented to maximize opportunities and ensure best practices.
6. Incident investigation—System feedback mechanisms are established to promptly assess success and failures. Lessons learned are promptly communicated and leveraged throughout the organization.
7. Audits—Self-evaluations are periodically conducted to compare performance to standards and implementation of system best practices. Results are reported and improvements monitored until fully implemented.

Injury and illness prevention programs have evolved beyond “initial behavioral” safety programs (e.g., OSHA Voluntary Protection Program (VPP), DuPont STOP Program) and include the next generation of worker behavior modification systems (e.g., Behavioral Safety Technology and Predictive Solutions), which has a predictive element and supports “unsupervised real-time behavioral change.”

Two specific examples of systems of prevention applied to mechanical energy are machine guarding and energy control.

Machine guarding

Mechanical energy and machine guarding are part of the greater system of engineering controls. The system consists of a single unit of equipment and the associated production process, including raw materials, manufacturing process to modify materials, employee interaction in the process, and the general work environment. All these factors are interdependent. The work area must be assessed as a 360° environment, with special emphasis on exposure to mechanical energy to help identify mechanical exposure and guarding/control. Failures in the system can result in contact with mechanical energy and ultimately injuries. A list of commonly encountered machines is included in Table 5.6, and definitions used in machine guarding are listed in Table 5.7.

One or more methods of machine guarding are required to protect employees.⁶ Machine guarding regulatory requirements have been published and applied to broad classes of equipment. Common hazards have been recognized through industrial experience and are roughly classified as point of operation, ingoing nip points, rotating parts, flying chips, and sparks.

Point of operation presents the most common and generally obvious hazard potential. These hazards occur where materials are modified, and the employee is usually in close proximity to moving equipment and raw materials.⁷Table 5.8 lists regulatory requirements for specific controls designed to eliminate access to the points of operation, specifically the power press design criteria for the distance of guards from a “danger zone” or point regulatory design criteria. The guarding device shall be in conformity with any appropriate standards therefore, or, in the absence of applicable specific standards, shall be so designed and constructed as to prevent the operator from having any part of his body in the “danger zone” during the operating cycle.

Distance of opening from point of operation hazard	Maximum width of opening
½ to 1½	1/4
1½ to 2½	3/8
2½ to 3½	1/2
3½ to 5½	5/8
5½ to 6½	3/4
6½ to 7½	7/8
7½ to 12½	1¼
12½ to 15½	1½
15½ to 17½
17½ to 31½

One or more types of controls, machine guarding, and protective methods must be employed to properly protect employees and meet regulatory requirements. The most common mechanical hazards are present at the point of operation (see definitions), during power transmission, and at a number of locations as materials are processed with equipment. Aside from traditional physical machine guards, there are a number of presence-sensing devices, hand removal or restraint devices, and two-hand trip devices that help prevent contact with moving machine parts and tools. The most common devices are:

1. Presence-sensing devices—Prevent normal press operation if the operator’s hands are inadvertently within the point of operation, prevent the initiation of a stroke, or stop a stroke in progress, if a body part, material, or device passes into an electronic sensing field. Presence-sensing devices like machine guards have specific regulatory requirements (see 29 CFR—1910 Appendix A to 1910.217). The employer is ultimately responsible for ensuring (in this case) that the regulatory certification/validation requirements are met.
2. Hand removal devices—Automatically withdraw the operator’s hands if the operator’s hands are inadvertently within the point of operation.
3. Two-hand trip/control devices—Require two hands to trip/operate the equipment. For instance, the operator must simultaneously depress two buttons located on each side of the operator. Thus the operator must have his hands out of the danger zone to activate the equipment. Design criteria for the use of two-hand control devices and calculation of the distance from the sensing field to the point of operation are essential elements in a safety design.

Other common devices for preventing operator contact with mechanical energy include the following:

1. Special hand tools for placing and removing material into equipment points of operation. These tools are designed to permit easy handling of material without the operator placing a hand in the danger zone. Such tools shall not be in lieu of other guarding required by this section, but can only be used to supplement protection provided.
2. Gates or movable barrier devices are barriers arranged to enclose the point of operation. The gates must be in place before the press/equipment can start a part of or a new production/machine cycle.
3. Holdout or restraint devices are mechanisms that prevent an operator’s hands from entering the point of operation. The operator’s hands are secured with cables (i.e., cord, metal cable), and the cables are adjusted and secured to ensure that the operator cannot reach into a point of operation.
4. Pullout devices are mechanisms attached to the operator’s hands and to a movable equipment part. These must be adjusted to each worker’s unique physical characteristics; they pull the operator’s hands away from the point of operation or danger zone. They operate inversely to the movement of the equipment. As a point of operation is reaching its most hazardous point (i.e., mechanical energy is transferred as work is performed), this device pulls the worker’s hands back to a point beyond the danger zone.
5. Sweep devices are arms or bars that move the operator’s hands to a safe position as the equipment cycles. They will literally sweep the operator’s hands away from the danger zone as the machine cycles.

Managing hazardous energy

Lockout/tagout programs are one of the most common methods to control mechanical energy during equipment maintenance, adjustment, or repair. The standard 29 CFR 1910.147—The Control of Hazardous Energy Lockout/Tagout—applies during maintenance, repair, or equipment adjustment and does not apply to normal production operations. Important definitions of the standard are listed in Table 5.9. The primary objective of the standard is to eliminate or manage the unexpected “energization” or start-up of the machines or equipment or release of stored energy that could cause injury to employees.

Managing hazardous energy requires employers to establish programs and utilize procedures to control or eliminate uncontrolled hazardous energy. This program must include procedures, practices, and training to ensure that contact with energized equipment or equipment components is managed and includes appropriate lockout and tagout devices that isolate and/or disable machines or equipment to prevent unexpected energization, start-up, or release of stored energy in order to prevent injury to employees.⁸

Employee protection and energy elimination and isolation are the goals of lockout/tagout. This requires that the employer demonstrate that the tagout program will provide a level of safety necessary to ensure no contact occurs with energized equipment or machinery. The employer shall demonstrate full compliance with all tagout-related provisions of the standard. Additional means of protection must be considered including periodic inspection of the lockout tagout program.

Procedures need to be developed, documented, and utilized for the control of potentially hazardous energy when employees are engaged in lockout/tagout activities.

The procedures need to clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance include, but not limited to, the following:

1. A specific statement of the intended use of the procedure
2. Shutting down, isolating, blocking, and securing machines or equipment
3. Placement, removal, and transfer of lockout/tagout devices:
   1. Lockout/tagout devices are locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware for isolating, securing, or blocking of machines or equipment from energy sources and must be provided. These tags must be standardized, easily identifiable, and only used for controlling energy. Lockout devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal-cutting tools.
   2. Tagout devices, including their means of attachment, shall be substantial enough to prevent inadvertent or accidental removal.
4. Responsibility for ensuring that lockout/tagout devices are utilized and who will ensure that this is done
5. Testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, blocks, and other energy control equipment
6. Procedures for reenergizing equipment and removing lockout/target devices

Training and communication

Employers should provide training to ensure that employees understand the purpose and function of all energy control programs and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. Examples of the training recommendations for the lockout/tagout regulations are included in Table 5.10; they are generalizable to training for all control technologies.

Periodic inspection

The final component of the systems approach is to inspect existing controls to ensure continued optimum operation. The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that all equipment lockout/tagout procedures and the requirements of this standard are fully implemented.

The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected and shall be conducted to correct any deviations and or areas requiring improvement.

Where tagout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized and affected employee, of that employee’s responsibilities under the energy control procedure being inspected.

The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.

Utilization of as many of these principles of prevention as possible will maximize production and safety and minimize injuries from mechanical hazards in the workplace.