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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
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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