Specific OSHA Requirements
OSHA requirements for the prevention of injuries caused by being struck by, struck against, or caught in machinery are contained primarily in 29 CFR 1910 Subparts J, N, and O.
Additional explanation of the OSHA requirements for the control of hazardous energy can be found in OSHA's Small Business Handbook (PDF) (OSHA Publication 2209-02R).
Other useful OSHA publications and documents are:
NOTE: Employers in states with state-run safety and health plans should check with their state agency. Their state may enforce standards that, while "as effective as federal standards," may not be identical to the federal requirements.
This section focuses on the injuries caused by being struck by, struck against, or caught in machinery. Contributing factors include a lack of machine guarding and Lockout/Tagout procedures, as well as failure to follow safety practices for forklifts, trucks, and storage.
What types of injuries can result from being struck by, struck against, or caught in machinery?
- Minor cuts and lacerations;
- Serious fractures, puncture wounds, amputations; and
What steps can an employer take to analyze the worksite for these types of hazards?
- Determine existence of forklifts and machinery with moving parts.
- Conduct a job hazard analysis to evaluate each piece of equipment for all energy sources.
- Evaluate housekeeping and storage procedures.
Specific contributing factors
Lack of Machine Guarding
Machine guarding ranks among the top 10 in numbers of OSHA citations issued.
Why do machine guarding injuries and fatalities occur?
- Production Demands
- Employees, to increase the work pace, often remove machine guards. This is especially true if employees receive a production incentive.
- Machine Design
- New machinery is often designed with all hazardous moving parts guarded.
- Older machinery will often need to be retrofitted with guarding devices. Machinery that has not been retrofitted exposes employees to the hazardous moving parts. If the machinery cannot be retrofitted with a guard, alternate methods of safe guarding are used, such as light curtains, presence sensing mats, two-hand controls, and/or guarding by location/distance.
- Machine Adjustments
- Guards are often removed to make adjustments to machinery. If not replaced before operation, employees are exposed to the hazardous area.
- Clearing Jams
- When the production line jams, employees often remove or bypass guards to clear the jam.
- When machinery is cleaned, guarding is often removed to ensure adequate cleaning and sanitation is performed.
- Lack of Management Commitment
- Production demands may take precedence over safety.
- Group or team employee incentives can result in peer pressure.
- There may be a lack of supervision and hazard identification.
- Attention may not be paid to safety and health.
- Employee involvement may not be used for:
- Production line layout, and
- Equipment purchase.
What can employer and employees do to prevent injuries from lack of machine guarding?
- Maintain in place guards that are supplied with machinery.
- Retrofit older equipment with appropriate guards.
- Use alternate methods of safeguarding where machine guards cannot be used.
- Do not remove or defeat guards in order to increase production rates.
- When it is necessary to remove guards to adjust machines, clear jams, or perform clearing operations, follow an established lockout/tagout procedure or otherwise protect employees.
Employee Training for Machine Guarding
- Employees need to know how machine guards are used, and why they are used.
- Training should include:
- Identification and description of the hazards associated with the machine;
- The type of guarding (how the guard protects);
- How to use the guard properly;
- When the guard can be removed;
- How the guard is removed;
- Who is authorized to remove the guard;
- What do to if a guard is damaged, missing, or does not provide adequate protection; and
- No independent actions taken by the employee. If in doubt, involve supervision.
Lack of Lockout/Tagout (LO/TO) Procedures
Approximately 39 million workers are protected by the Lockout/Tagout rule.
Compliance with the regulation will prevent about:
- 122 fatalities each year,
- 28,400 lost workday injuries, and
- 31,900 non-lost workday injuries.
What is lockout/tagout?
LO/TO is used to control all sources of hazardous energy during servicing and maintenance of machinery.
Energy sources include:
- Chemical, and
Lockout involves physically locking access to the control of the energy source to prevent any unexpected energization, startup, or release of stored energy that could injure a worker. Each worker must have his own lock.
Tagout involves placing tags on machinery that is not capable of being physically locked out to warn employees that serving or maintenance is being performed. Tags do not provide the physical restraint of a lock. Lockout is the preferred method of energy control.
REMEMBER: There can be multiple energy sources on a single machine. All sources need to be locked out or tagged.
- Some servicing and adjustment operations must be performed with the power on (i.e., fine adjustments, and identifying the source of a problem). Employees must be protected during these situations.
- If power is not required during servicing or adjustments, Lockout/Tagout procedures are required.
- Minor tool changes, adjustments, and/or minor servicing activities that are routine, repetitive, and integral to the use of production equipment and that occur during normal production operations are not covered by the Lockout/Tagout standard.
Equipment Requirements for Lockout/Tagout
- An adequate number of locks for each employee involved in the job. If multiple energy sources are present, multiple locks for each employee will be needed.
- Lockout hasps for multiple employees needing to lockout a single energy source.
- An adequate supply of tags.
Employee Training for Lockout/Tagout
- All employees covered by the Lockout/Tagout standard must be trained on the purpose, function, and restrictions of the energy control program.
- Employees performing servicing and adjustments must be able to recognize all hazardous energy sources and understand the methods of isolation and control of these energy sources.
- Training must be done initially when an employee is first covered by this standard and must reoccur as necessary.
- The employer must certify that employees have received effective training. The certification must contain the employee's name and the dates of the training.
- Retraining is required when:
- There is a change in job assignment,
- There is a change in machines,
- New equipment that presents a new hazard is introduced to the workplace,
- There is a change to a company's Lockout/Tagout program, and
- The employer has reason to believe there are inadequacies in the employee's knowledge of the Lockout/Tagout program.
Failure to Follow Forklift Safety Practices
Forklift safety practices include:
- Elevated Work Locations
- Prohibit employees from standing on forklift forks to access elevated locations. If a forklift is used as a lift device for employees, a work platform designed specifically for this purpose is needed. A back guard is also needed on the side of the platform nearest the mast frame to prevent any part of the body from being caught.
- Condition of the Forklift
- Install overhead guards on forklifts if there is potential for a load to fall onto the operator.
- General Maintenance
- Inspect all forklifts.
- Equip forklifts with a horn that is clearly audible over the background noise of the work environment. The horn is an important warning device to alert employees working near a forklift of its presence.
- Lights are needed on forklifts that are used in areas with inadequate lighting. Lights allow the operator to see hazards that may make the forklift unstable and to see persons in the path of the forklift.
- The brakes of the forklift need to be maintained in excellent condition. Parking brakes also need to function well to prevent unexpected movement of the forklift.
- Train all employees who operate forklifts.
- Training must be provided annually.
- Make sure the weight of the load never exceeds the capacity of the forklift.
- Non-Driver Awareness
- Operators are not the only employees at risk for forklift related injury. All employees in the work area must exercise caution when forklifts are used. All employees need to be aware of
forklifts and respect the dangers by staying out of the way.
- Standing/Working under Raised Forks
- Repair work that must be performed under raised forks must be performed with caution. A physical block must be placed under the forks to prevent the forks from dropping and crushing the employee should the hydraulic system fail.
- When the forks are elevated, employees should be prohibited from standing under the area immediately adjacent to the forks because the forks or objects may fall.
Failure to Follow Truck Safety Procedures
Truck safety procedures include:
- Caution must be used around loading docks.
- Employees need to be aware of delivery trucks in motion. When a truck is being moved into or out of a loading dock, the driver is not fully able to see everything behind the vehicle. This can result in persons being run over by the vehicle's wheels or being crushed between a loading dock and the back of the truck. Having an employee direct the driver while backing up, or using audio or visual warning devices can warn employees of the potential hazards.
Failure to Follow Safe Shelving Procedures
Safe shelving and storage procedures include:
- Store heavy items on lower shelves.
- Do not stack items so high as to be unstable.
- If shelves are multilevel, there must be appropriate equipment available to access items stored on higher shelves. Prohibit employees from climbing storage shelves to access upper shelves because of the risk of falling. Use Forklifts, ladders, order pullers, or other methods of accessing high shelves.
- Shelving Units
- Make sure the capacity of the shelves is clearly indicated on the shelving units and do not exceed it. Excess weight can cause the shelves to collapse.
- A shelving unit system's vertical supports can be damaged when hit by forklifts. Damage to the support system can jeopardize the integrity of the shelving system.
- Secure shelving units to prevent the units from falling.
- Long hair can be a hazard around moving machinery. It can get caught in moving parts and pull the employee into the hazardous area. Restrain long hair in a hair net or style it to ensure that it will not get caught in the machinery.
- Long dangling jewelry can get caught in the moving parts of machinery and pull the employee into the hazardous area. Rings can also get caught on moving parts, so employees must use caution around machinery if jewelry is worn, or better yet, not wear it.
- Loose clothing can get caught in the moving parts of machinery and pull the employee into the hazardous area. Make sure loose clothing is not worn around machinery.
- If hands need to be near the hazardous moving part of a machine, gloves should not be worn. Gloves can get caught in the moving parts and pull the employee's hands and arms into the machine.