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Case Study 1: Printing Press Roll Cleaning
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.
For more information: Read
the
Printing Presses: requirements for normal production and servicing operations of the Printing
Industries of America, Inc., for details on how to use safe alternative measures for
printing presses.
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