• Record Type:
    OSHA Instruction
  • Current Directive Number:
    CPL 2-1.24
  • Old Directive Number:
    CPL 2-1.24
  • Title:
    National Emphasis Program on Mechanical Power Presses, 29 C.F.R. 1910.217.
  • Information Date:
  • Standard Number:
Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 6, 1997

MEMORANDUM TO:ALL REGIONAL ADMINISTRATORS

ATTENTION:MECHANICAL POWER PRESS NEP COORDINATORS

FROM:JOHN B. MILES, JR., DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:Correction for OSHA Instruction CPL 2-1.24, National Emphasis Program on Mechanical Power Presses, 29 CFR 1910.217

The purpose of this memorandum is to provide the field with interim change pages for the recently released Directive on the National Emphasis Program for Mechanical Power Presses. Page G-16 of the Directive inadvertently included a paragraph describing an 8-hour training requirement for press operators. No such requirement exists in the standard at 1910.217, and the error has been corrected in the attached pages. Please ensure that all Area Office, State Plan and appropriate Regional personnel receive a copy of this correction notice.

We will be at some point in the future publish a formal Change 1 to this Directive. This memorandum is meant to avoid any further confusion and provide clarification to the regulated community.



OSHA Instruction CPL 2-1.24
February 28, 1997
Directorate of Compliance Programs

SUBJECT: National Emphasis Program on Mechanical Power Presses, 29 C.F.R. §1910.217.

A. Purpose. This directive describes policies and procedures for implementing a National Emphasis Program (NEP) to reduce and eliminate the workplace incidence of hazards associated with mechanical power presses.

B. Scope. This instruction applies OSHA-wide. The OSHA program is delivered in 40% of the nation's workplaces by the 25 states that operate OSHA approved state plans. These states are encouraged to adopt similar policies but may choose to develop and implement alternatives. See paragraph F.

C. References.

1. OSHA Instruction CPL 2.102, March 28, 1994, Procedures for Approval of Local Emphasis Programs and Experimental Programs.

2. OSHA Standard 29 CFR §1910.217.

3. OSHA's Safety and Health Management Guidelines, 54 FR 3904, January 26, 1989.

4. OSHA Instruction CPL 2.25I, January 4, 1995, Scheduling System for Programmed Inspections.

5. Executive Order 12196, Section 1-201.

6. OSHA Standard 29 CFR 1960.16.

7. OSHA Instruction STP 2.22A, CH-2, January 29, 1990, State Plan Policies and Procedures Manual(SPM).

8. OSHA Instruction CPL 2.103, September 26, 1994, Field Inspection Reference Manual (FIRM).

D. Action. The policies and procedures set forth in this directive are effective immediately. OSHA Regional Administrators, Area Directors and National Office Directors shall ensure that the policies and procedures set forth in this directive are followed.

Regional Administrators shall also ensure that the State Consultation Program Managers and the State Plan State Designees in their Regions are apprised of the contents of this NEP and its required Area Office Outreach initiatives. Regional Administrators are to encourage the Consultation Programs' involvement in this Agency-wide effort.

E. Application. This instruction applies to inspections of general industry employers whose workplaces include mechanical power presses.

F. Federal Program Change. This instruction impacts State programs. Each Regional Administrator shall:

1. Ensure that this change is promptly forwarded to each State designee, using a format consistent with the Plan Change Two-Way Memorandum in Appendix P, OSHA Instruction STP 2.22A, CH-2, SPM.

2. Explain the content of this change to the State designee.

3. Ensure that States are encouraged, but not required, to adopt an identical or alternative policy. States shall be asked to provide preliminary notification to the Regional Administrator within 30 days from the date of this introduction of their intent to adopt or not to adopt the procedures in this directive. The State shall formally respond to this change with an indication of their intent within 70 days in accordance with paragraph I.1.a.(2)(a) and (b), Chapter III or Part I of the SPM. If the State adopts identical procedures, no further plan change supplement need be submitted. If the State adopts different compliance procedures, a copy of the procedures shall be provided to the Regional Administrator within six months from the date of this directive for review.

4. Review policies, procedures, and instructions issued by the State and monitor their implementation as provided in a Performance Agreement or through routine monitoring focussing on impact and results.

G. Background. OSHA has determined that a National Emphasis Program is needed because of the continuing incidence of injuries that have resulted from the operation of mechanical power presses. The hallmark of OSHA's enforcement policy is achieving optimal worker protection. Under The New OSHA, National Performance Review, May 1995, enforcement policies consider both an employer's efforts at adopting protective measures and its efforts toward the abatement of hazards.

The operation of a mechanical power press can be extremely dangerous and compliance with OSHA's mechanical power press standard is frequently overlooked. Injuries involving mechanical power presses often result in death or permanent disability and OSHA's inspection history indicates that employee exposures to these hazards are prevalent in many workplaces. Section 1910.217 provides for safety measures that need to be undertaken regarding the safe operation of mechanical power presses. This NEP provides additional information on how to identify and guard against these hazards.

H. Program Procedures. This NEP includes three major field activities: outreach, targeting/selection, and inspection. The outreach phase of the Program is to begin 30 days from the effective date of this directive. Inspections are to begin 90 days after the outreach period is initiated.

1. Outreach. Each Regional and Area Office shall concurrently develop outreach programs that support the purpose of this NEP, to reduce and eliminate workplace hazards associated with mechanical power presses. Programs may include letters to employers, professional associations, and local unions or other activities designed to involve labor and management stakeholders in the elimination of power press hazards. The Office of Information and Consumer Affairs will provide support to the Regional and Area Offices.

At the discretion of the Regional and Area Offices, outreach materials may either be mailed directly or made available upon request to employers, professional associations, and local unions. The attached appendices provide useful information which may be used, in whole or in part, by the Regional and Area Offices.

2. Site Selection. Inspections conducted under this NEP shall be scheduled and conducted pursuant to the following priorities. Inspections shall concentrate on particular establishments where work-related injuries are likely or where there have been known injuries involving mechanical power presses. The following is a list of sources for obtaining information to develop a roster from which inspections will be conducted.

a. Standard Industrial Classification (SIC) Codes. The table below represents national data on the ten SICs with the highest number of 29 CFR §1910.217 violations for the period September, 1990 through February,1996. Each Area Office shall either use these SICs, or prepare its own list of establishments for the top ten (10) SIC codes in the Area Office's jurisdiction, based on IMIS data from the previous three years. Establishments with fewer than ten employees are to be included in this Program. Consult the current appropriation riders for exempt employers in any given SIC (see the current version of OSHA Instruction CPL 2.51 for exempt SICs for any given fiscal year).

Rank
All federal states
(10/1/90-2/23/96)
1. 3469(204) stamping
2. 3444(135) sheet metal
3. 3442(92) metal doors
4. 3441(68) fab. steel
5. 3429(60) hardware
6. 2542(60) manuf. furniture
7. 3714(56) motor vehicles
8. 3499(48) misc. metal
9. 3443(44) boiler shops
10. 3496(39) wire


b. Additions to list based on local data. Area Offices shall attempt to obtain and use additional data to further identify and add establishments where serious injuries or fatalities related to power presses have occurred in the last three years. Local information could include, where available, workers' compensation data, OSHA 200 data, and hospital discharge data. The basis for addition of an establishment shall be documented.

c. Each establishment on the list shall be given a sequential number. Establishments that are added based on paragraph (b) above may be added to the bottom of the list or inserted elsewhere in the list within a similar SIC category. Administratively neutral criteria shall be applied when selecting from the list of establishments developed from the SIC Codes and local data. The random numbers table (see OSHA Instruction CPL 2.25I) shall be used to identify individual establishments to be inspected. Area Offices may delete facilities that are not likely to have hazards associated with mechanical power presses or firms which are known to be out of business, documenting the basis for such determination. Further, in accordance with the FIRM, any establishment having had a safety inspection in the last three years shall be deleted from the list.

d. Program approval. Each Area Office's inspection program must be approved by the Regional Administrator and the Regional Solicitor. This is most easily accomplished by setting out the targeting and selection system in a Regional Program Directive, as for a Local Emphasis Program. Other forms of documentation may, however, be used at the discretion of the Regional Administrator.

3. Inspection Procedures. Inspections initiated under this NEP shall be scheduled and conducted in accordance with provisions of the FIRM, except as noted below.

a. Inspections will be limited to hazards associated with mechanical power presses, but the CSHO may expand the scope of the inspection beyond mechanical power presses if other hazards or violations are observed. Inspections shall be scheduled beginning the current fiscal year, and will continue until further notice.

b. Because the nature of this program may yield a number of significant cases, Area Directors, Supervisors, and CSHOs should ensure that the requirements for case development are being met.

I. Scheduling and Resource Allocation.

1. This is a National initiative, which affects existing inspection scheduling priorities, as indicated below. Area Offices shall develop and implement targeting systems which are suited to the Region's resources and the needs of workers in their jurisdictions.

a. Resources. Regional Administrators shall ensure that adequate resources are designated for this NEP.

b. Planning. Each Regional Administrator shall report, to the Director of Compliance Programs, the number of NEP inspections that are planned for each quarter of the fiscal year, and shall report, 30 days after the end of each quarter, the number of such inspections actually conducted.

c. Priority. Inspections conducted under this NEP have a lower priority than inspections conducted under Cooperative Consultation Programs (CCP), but have a higher priority than other programmed inspections. Where possible, mechanical power presses can be inspected during CCP inspections.

d. Conflicts. Other National, Regional or local Programs, including redesigned Area Office activities/problem solving initiatives, may compete with this NEP for available staff resources. Nonetheless, conflicts must be resolved to ensure that the NEP is implemented in each Area Office. Thus, this NEP may be combined with other initiatives which identify targets on a different basis. For example, a Local Emphasis Program (LEP) which targets specific industries, rather than hazards, may be combined with this NEP by addressing the relevant hazards as part of a combination NEP/LEP inspection.

J. Coordination.

1. National Office. This NEP will be coordinated in the Office of Safety Compliance Assistance, Directorate of Compliance Programs. Questions and comments should be directed to the National Coordinator in that Office.

2. Field. Each Regional Administrator shall name a coordinator for this National Emphasis Program.

K. Consultation Programs. The National Office has involved the State Consultation Program with the development of this NEP. Activities are underway to incorporate state consultative services concurrently into the outreach/enforcement approach of this program. Special efforts will be made at the National Office level to ensure that consultation staff is offered training courses and outreach materials. Similarly, Area Offices within the same state jurisdiction are strongly encouraged to include their state 7(c)(1) program contacts in the development and implementation of their local program. The State Consultation Program will also be encouraged to develop their own strategic approaches to address the need to reduce injuries and accidents related to power presses.

L. Training. Because of the technical nature of mechanical power presses, CSHOs who conduct inspections under this NEP and consultation staff must have had adequate training or experience with mechanical power presses.

1. The OSHA Training Institute (OTI). The OTI provides training materials to CSHOs, consultation staff, and, employers. Also, additional sessions of the OTI's mechanical power press course can be made available. Technical training at the OTI can be expanded to include the use of a time-stop measuring device to measure the safety distance on a power press, should it be determined that such training is needed.

2. Additional Training.

a. On-the-Job Training. Area Directors and supervisors shall ensure that inexperienced CSHOs also receive on-the-job training by accompanying experienced compliance officers during power press inspections.

b. Enforcement and Compliance Issues. Continuing guidance regarding enforcement and compliance issues will be provided as new issues arise.

M. Federal Agencies. This instruction describes a change that affects Federal agencies. Executive Order 12196, Section 1-201, and 29 CFR §1960.16, maintains that Federal agencies must also follow the enforcement policy and procedures contained in this Directive.

N. Program Evaluation. Area Offices shall collect data relevant to the effectiveness of this NEP and submit it to the Regional Office. The Regional Office, after summarizing the information, will forward it to the National Office at the end of the year. At a minimum the evaluation should respond to the requirements of CPL 2.102 G.4. Evaluations.

O. IMIS Coding.

1. Current instruction for completing enforcement forms OSHA-1, OSHA-7, OSHA-36, and OSHA-90 and Consultation Request Form-20 and Visit Form-30 shall be applied when recording inspections conducted under this NEP as follows:

a. The OSHA-1 Form for any programmed inspection covered under this national emphasis program for mechanical power presses in all industries shall be marked "PLANNED" (Item 24h) and "NATIONAL EMPHASIS PROGRAM" (Item 25d). Record PWRPRESS in the space in item 25d.

b. The OSHA-1 Form for any unprogrammed inspection shall be marked as unprogrammed (Item 24a through gas appropriate). In addition, it shall be marked "NATIONAL EMPHASIS PROGRAM" (Item 25d). Record PWRPRESS in the space item 25d.

c. Whenever an OSHA-7 is completed by a Federal office and the applicable complaint alleges the presence of power press-related hazards, complete the OSHA-7 in the usual manner, but include the code for power presses in "Optional Information" Item No. 46. The following format should be used:


TYPEIDVALUE
N16PWRPRESS


d. Whenever an OSHA-36 is completed by a Federal office and the inspecting CSHO is able to identify at the site of the fatality / catastrophe the existence of power press-related hazards, complete the OSHA-36 in the usual manner, but include the code for Power presses in "Optional Information" Item No. 35. The following format should be used:


TYPEIDVALUE
N16PWRPRESS


e. Complete the OSHA-90 in the usual manner and enter the code for power presses in "Optional Information" Item No. 26, when an OSHA-90 is completed by a Federal office and the applicable referral case has power presses as one of the subjects of the file. The following format should be used:


TYPEIDVALUE
N16PWRPRESS


2. Consultation.

a. Whenever a visit is made in response to this NEP, a Consultation Request Form and / or Visit Form is to be completed as follows:

(1) Complete the Consultation Request Form-20 in the usual manner and enter the code for power press in "Optional Information" Item No. 26, when a visit has been made in response to the NEP. The following information should be used:


TYPEIDVALUE
N16PWRPRESS


(2) Complete the Visit Form-30 in the usual manner and enter the code for power presses in "Optional Information" Item No. 34, when a visit has been made in response to the NEP. The following in formation should be used:


TYPEIDVALUE
N16PWRPRESS


P. Appendices. The Appendices contain a variety of information developed to assist employers, employees, and compliance officers in the implementation, training and outreach requirements of this Program. The Area Office may use its discretion in selecting whatever materials deemed appropriate and feasible for outreach purposes.

Appendix A: Useful Formulas: Safety Distances and Table 0-10

Appendix B: Full Revolution Clutch Presses support materials

-- Summary of applicable 217 provisions

-- Safety distance formula and graph

-- A partial list of engagement points

-- Weekly inspection report -- sample

-- Monthly inspection report -- sample

Appendix C: Part Revolution Clutch Presses support materials

-- Summary of applicable Section 1910.217 provisions

-- Safety distance formula and graph

-- Weekly inspection report -- sample

-- Periodic inspection report -- sample

Appendix D: Sample pullout/restraint inspection checklist

Appendix E: Safeguards and other hazards

Appendix F: Point of Operation injury sample report

Appendix G: Mechanical Power Presses -- Questions and Answers



Greg Watchman
Acting Assistant Secretary

DISTRIBUTION:
National, Regional, and Area Offices
All Compliance Officers
State Designees
NIOSH Regional Program Directors
7(c)(1) Project Manager




Appendix A: Press Safety Distances

A. Use of Table. It shall be the responsibility of the employer to provide and insure the usage of Point of Operation guards or properly applied and adjusted Point of Operation devices on every operation performed on a mechanical power press except when the Point of Operation opening is one-fourth inch or less. When the opening exceeds one-fourth inch, then Table A.1 must be followed.

TABLE A.1

Distance of Opening from Point
of Operation Hazard (inches)
Maximum width of opening
(inches)

1/2 to 1-1/2
1-1/2 to 2-1/2
2-1/2 to 3-1/2
3-1/2 to 5-1/2
5-1/2 to 6-1/2
6-1/2 to 7-1/2
7-1/2 to 12-1/2
12-1/2 to 15-1/2
15-1/2 to 17-1/2
17-1/2 to 31-1/2

1/4
3/8
1/2
5/8
3/4
7/8
1-1/4
1-1/2
1-7/8
2-1/8


B. Safe Distance, Part Revolution Press. Stopping time is measured in hundredths of a second, multiplied by 63 inches. The easiest way to calculate safe distance is to move the decimal over like this. If stopping time was measured at ½ second or 500 milliseconds, the minimum safe distance is ½ of 63 inches or approximately 2 ½ feet from the forward most Point of Operation. Remember 63 inches is approximately 5 feet. If stopping time was measured to be 100 milliseconds, then the minimum safe distance would be 6.3 inches. Always determine from examining all dies used in a particular press what the forward most Point of Operation is and then measure forward of it to locate your safety device. It's always a good idea once safe distance is calculated to note this right at the press with the following information:

1. Date of measurement

2. Stopping Time

3. Safe Distance Calculation

4. Added distance to allow for normal deterioration so that position of your safeguard does not have to be relocated after a short period of time.

5. Your forward most Point of Operation die location.

6. Your fixed location of your safety device or safe guard.

C. Safe Distance, Full Revolution Press. Safe distance on full revolution presses is directly related to continuous press speed and the number of engagement points in the clutch. The two hand trips become impractical as a primary safe guard, since in most cases, they would have to be relocated at such a distance from the Point of Operation that production would be reduced below an acceptable level. If the press had a multiple pin engagement clutch (14 points or more) and the press operated at a continuous speed of over 15 inches from the Point of Operation, then the two hand trip is practical. If the press has fewer engagement points or is slower, the consideration of another safe guard would be most practical.



Appendix B: Support Materials - Full Revolution Clutch Presses

A. Summary of Applicable Provisions of Section 1910.217 for Full Revolution Positive Clutch Presses.

1. Safeguarding:

a. Guards: Prevent entry of hands - (c)(2)(I)(a)

Conform to Table A-1 - (c)(2)(I)(b)

Use fasteners - (c)(2)(I)(c)

b. Pull-outs: (c)(3)(iv)(a, b, c, d)

c. Two Hand Trips: Protected, Both Hands, Concurrent Pressure - (b)(6)(I)

Anti-repeat - (b)(6)(ii)

Safe distance - (c)(3)(viii)(c).

You must:

(1) Obtain time for one revolution

(2) Obtain the number of engaging points

(3) Use Table A-1 to obtain safe distance

2. Inspections:

Weekly - (e)(1)(ii)

Periodic - (e)(1)(I)

Pull-outs - (c)(3)(iv)(d), only when used as the primary safeguard

3. Training:

Operator - (f)(2)

Maintenance - (e)(3)

4. Motor Controls:

Disconnect - (b)(8)(I)

Buttons - (b)(8)(ii)

Magnetic - (b)(8)(iii)

5. Single-stroke mechanism: (b)(3)(I), (ii)

B. Comparison Graph of minimum safety distances.

C. Partial List of Engagement Points - Full Revolution Presses.

# OF ENGAGEMENT POINTS PRESS MFG

14 NIAGARA ONLY

4 * BLISS * MINISTER
* PRESS RITE

3 ALVA ALLEN JOHNSON
VERSON * BLISS CLEARING
CLEVELAND CONSOLIDATED
DANLY DIAMONT FEDERAL
MINISTER
FERRACUTE L & J
TOLEDO * PERKINS
ROBINSON * ROBINSON
ROCKFORD ROUSELLE
V & O WALSH WILLIAM/WHITE

2 ALVA ALLEN KENCO
* BENCHMASTER *
PERKINS * GILRO *
PRESSRITE

1 * BENCHMASTER FAMCO
* GILRO

* NOTES SOME OVERLAP


D. SAMPLE FORM - Mechanical Power Press Weekly Inspection Record for Full Revolution Power

(The purpose of this form is to provide compliance assistance information to interested parties required to comply with Subpart O, 1910.217(e) regulations for mechanical power presses. This non-mandatory format has been developed to list components of machines common to most power presses, although it is not an exhaustive listing. The employer is responsible for consulting the manufacturer's recommendations on each power press in operation and fully complying with the letter and intent of 1910.217(e).

MACHINE NO._________________________  DEPARTMENT_________________________

DATE_____________________

       NOT                                                   DATE OF
 OK    OK    PART INSPECTED      IF NOT OK, CONDITIONS     CORRECTION

____  ____   Floor Condition
             Clean _____________________________________   ____________

____  ____   Lighting at Press _________________________   ____________

____  ____   Operator Properly
             Trained ___________________________________   ____________

____  ____   Lower & Upper
             Treadle ___________________________________   ____________

____  ____   Brake-Collar ______________________________   ____________

____  ____   Collar Key Strap,
             Fixed Half,Hinged Half,
             Hinge Pin, Adjustment Spring, 
             Band Nut Adjustment 
             Stud ______________________________________   ____________

____  ____   Latch Bracket,
             Latch Spring ______________________________   ____________

____  ____   Anti-Repeat _______________________________   ____________

____  ____   Single Stroke
             Mechanism _________________________________   ____________

____  ____   Air Gauge
             (condition-accuracy) ______________________   ____________

____  ____   Air Cylinder/Valves _______________________   ____________

____  ____   Push-Palm Buttons
             & Wiring __________________________________   ____________

____  ____   Two Hand Trips at
             Safe Distance _____________________________   ____________

____  ____   Safeguard Adjusted to
             Table 0-10 ________________________________   ____________

____  ____   Relays, Switches, etc. ____________________   ____________


COMMENTS:______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________

INSPECTED BY:__________________________________________________________
_______________________________________________________________________
                          (Name and Job Title)

PRESS APPROVED FOR OPERATION _______________________________________
RED TAGGED


E. SAMPLE FORM - Mechanical Power Press Periodic Inspection Record for Full Revolution Power Presses.

(The purpose of this form is to provide compliance assistance information to interested parties required to comply with Subpart O, 1910.217(e) regulations for mechanical power presses. This non-mandatory format has been developed to list components of machines common to most power presses, although it is not an exhaustive listing. The employer is responsible for consulting the manufacturers recommendations on each power press in operation and fully complying with the letter and intent of 1910.217(e).

MACHINE NO._________________________  DEPARTMENT_________________________

DATE_____________________

       NOT                                                   DATE OF
 OK    OK    PART INSPECTED      IF NOT OK, CONDITIONS     CORRECTION

____  ____   Floor Condition Clean _____________________   ____________

____  ____   Piping to Press
             (air power) _______________________________   ____________

____  ____   Lighting at Press _________________________   ____________

____  ____   Operator Properly
             Trained ___________________________________   ____________

____  ____   Bolster Plate
             Secure ____________________________________   ____________

____  ____   Inclining Screw,
             Ratchet,Screw Pin,
             Cotters for
             Screw Pin _________________________________   ____________

____  ____   Lower & Upper
             Treadle ___________________________________   ____________

____  ____   Tie Rods __________________________________   ____________

____  ____   Leg Clamp &
             Pivot Bolt ________________________________   ____________

____  ____   Brake-Collar ______________________________   ____________

____  ____   Collar Key Strap, Fixed
             Half, Hinged Half, Hinge
             Pin, Adjustment Spring,
             Band Nut Adjustment Stud __________________   ____________

____  ____   Latch Bracket,
             Latch Spring ______________________________   ____________

____  ____   Flywheel End
             Collar Pin ________________________________   ____________

____  ____   Anti-Repeat _______________________________   ____________

____  ____   Single Stroke Mechanism ___________________   ____________

____  ____   All Parts & Screws Secure _________________   ____________

____  ____   Frame & Base for Cracks ___________________   ____________

____  ____   Bearing Clearances ________________________   ____________

____  ____   Slide-Jib Clearance _______________________   ____________

____  ____   Main-Drive (belts, gears) _________________   ____________

____  ____   Air Gauge 
             (condition-accuracy) ______________________   ____________

____  ____   Air Cylinder/Valves _______________________   ____________

____  ____   Push-Palm Buttons
             & Wiring __________________________________   ____________

____  ____   Ground Fault Potential ____________________   ____________

____  ____   Lubrication System ________________________   ____________

____  ____   Two-Hand Trips at Safe 
             Distance __________________________________   ____________

____  ____   Safeguard Adjusted to
             Table 0-10 ________________________________   ____________

____  ____   Safeguard Interlocks ______________________   ____________

____  ____   Motor Controls ____________________________   ____________

____  ____   Relays, Switches, etc. ____________________   ____________

COMMENTS:______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________

INSPECTED BY:__________________________________________________________
_______________________________________________________________________
                          (Name and Job Title)

PRESS APPROVED FOR OPERATION _______________________________________
RED TAGGED




Appendix C: Support Materials - Part Revolution Clutch Presses

A. Summary of Applicable Provisions of Section 1910.217 for Part Revolution Positive Clutch Presses.



Summary of Applicable Provisions of Section 1910.217 for Part Revolution Positive Clutch Presses (continued).



B. Comparison Graph of minimum safety distances.



C. SAMPLE FORM - Mechanical Power Press Weekly Inspection Record for Partial Revolution Power Presses.

(The purpose of this form is to provide compliance assistance information to interested parties required to comply with Subpart O, 1910.217(e) regulations for mechanical power presses. This non-mandatory format has been developed to list components of machines common to most power presses, although it is not an exhaustive listing. The employer is responsible for consulting the manufacturers recommendations on each power press in operation and fully complying with the letter and intent of 1910.217(e).

MACHINE NO._________________________  DEPARTMENT_________________________

DATE_____________________

       NOT                                                   DATE OF
 OK    OK    PART INSPECTED      IF NOT OK, CONDITIONS     CORRECTION

____  ____   Floor Condition Clean _____________________   ____________

____  ____   Lighting at Press _________________________   ____________

____  ____   Operator Properly Trained _________________   ____________

____  ____   Brake-Collar ______________________________   ____________

____  ____   Collar Key Strap, Fixed
             Half, Air Cylinder Operating,
             Hinged Half, Hinge Pin,
             Adjustment Spring, Band
             Nut Adjustment ____________________________   ____________

____  ____   Push-Palm Buttons & Wiring ________________   ____________

____  ____   Ground Fault Potential ____________________   ____________

____  ____   Rotary Limit Switch Secure
             & Cams, Relays Secure &
             Adjusted __________________________________   ____________

____  ____   Main Control Cabinet Secure
             & Closed After Inspection for
             Oil, Grease, etc., and Proper
             Functioning of all Components,
             Devices Contained 
             Therein ___________________________________   ____________

____  ____   Main Motor Controls 
             Operating _________________________________   ____________

____  ____   Slide Adjust Motor Controls _______________   ____________

____  ____   Designated Wiring Secure
             at Proper Terminal Points _________________   ____________

____  ____   Foot Switch, Spring 
             & Wiring __________________________________   ____________

____  ____   Main Clutch Valves
             Operating _________________________________   ____________

____  ____   Brake Operating, Clean &
             Adjusted __________________________________   ____________

____  ____   Stopping Time at 90o
             Milliseconds ______________________________   ____________

____  ____   Safe Distance of 
             Safeguard OK ______________________________   ____________

____  ____   Anti-repeat _______________________________   ____________

____  ____   Barrier Guard Adjusted to
             Table 0-10 ________________________________   ____________


COMMENTS:______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________

INSPECTED BY:__________________________________________________________
_______________________________________________________________________
                          (Name and Job Title)

PRESS APPROVED FOR OPERATION _______________________________________
RED TAGGED _____________________


C. SAMPLE FORM - Mechanical Power Press Periodic Inspection Record for Partial Revolution Power Presses.

(The purpose of this form is to provide compliance assistance information to interested parties required to comply with Subpart O, 1910.217(e) regulations for mechanical power presses. This non-mandatory format has been developed to list components of machines common to most power presses, although it is not an exhaustive listing. The employer is responsible for consulting the manufacturers recommendations on each power press in operation and fully complying with the letter and intent of 1910.217(e).

MACHINE NO._________________________  DEPARTMENT_________________________

DATE_____________________

       NOT                                                   DATE OF
 OK    OK    PART INSPECTED      IF NOT OK, CONDITIONS     CORRECTION

____  ____   Floor Condition Clean _____________________   ____________

____  ____   Piping to Press (air,
             power) ____________________________________   ____________

____  ____   Lighting at Press _________________________   ____________

____  ____   Operator Properly 
             Trained ___________________________________   ____________

____  ____   Bolster Plate Secure ______________________   ____________

____  ____   Inclining Screw, Ratchet,
             Screw Pin, Cotters for Screw
             Pin _______________________________________   ____________

____  ____   Tie Rods __________________________________   ____________

____  ____   Leg Clamp & 
             Pivot Bolt ________________________________   ____________

____  ____   Brake-Collar ______________________________   ____________

____  ____   Collar Key Strap, Fixed Half,
             Air Cylinder Operating, Hinged
             Half, Hinge Pin, Adjustment
             Spring, Band Nut 
             Adjustment ________________________________   ____________

____  ____   Fly Wheel End Collar Pin __________________   ____________

____  ____   All Parts & Screws Secure _________________   ____________

____  ____   Frame & Base for cracks ___________________   ____________

____  ____   Bearing Clearances ________________________   ____________

____  ____   Slide-Jib Clearances ______________________   ____________

____  ____   Main-Drive (belts, gears) _________________   ____________

____  ____   Air Gauge 
             (condition-accuracy) ______________________   ____________

____  ____   Push-Palm Buttons
             & Wiring __________________________________   ____________

____  ____   Ground Fault Potential ____________________   ____________

____  ____   Rotary Limit Switch Secure
             & Cams, Relays Secure &
             Adjusted ___________

____  ____   Operator's Station Secure _________________   ____________

____  ____   Main Control Cabinet Secure
             & Closed After Inspection for
             Oil, Grease, etc., and Proper
             Functioning of all Components,
             Devices Contained 
             Therein ___________________________________   ____________

____  ____   Main Motor Controls 
             Operating _________________________________   ____________

____  ____   Slide Adjust Motor 
             Controls __________________________________   ____________

____  ____   Designated Wiring Secure at
             Proper Terminal Points ____________________   ____________

____  ____   Foot Switch, Spring &
             Wiring ____________________________________   ____________

____  ____   Lubrication Operating at all
             Designated Points _________________________   ____________

____  ____   Main Clutch Valves
             Operating _________________________________   ____________

____  ____   Brake Operating, Clean,
             Adjusted __________________________________   ____________

____  ____   Stopping Time at 90o
             Milliseconds ______________________________   ____________

____  ____   Safe Distance of Safeguard OK _____________   ____________

____  ____   Anti-Repeat _______________________________   ____________

____  ____   Barrier Guard Adjusted to
             Table 0-10 ________________________________   ____________


COMMENTS:______________________________________________________________
_______________________________________________________________________
_______________________________________________________________________

INSPECTED BY:__________________________________________________________
_______________________________________________________________________
                          (Name and Job Title)

PRESS APPROVED FOR OPERATION ______________________________________ 
RED TAGGED _____________________




Appendix D: Sample Pullout/Restraint Inspection Checklist

Each pull-out device or restraint in use shall be visually inspected and checked for proper adjustment at the start of each operator shift, following a new die set-up, and when operators are changed. Necessary maintenance, repair, or both shall be performed and completed before the press is operated.

MACHINE NO. ________________________  DEPARTMENT ______________________

OPERATOR I.D._______________________

DATE _______________  TIME ________________  SHIFT CHANGE _____________

DIE CHANGE ______________________  OPERATOR CHANGE ____________________

A SEPARATE DEVICE SHALL BE PROVIDED FOR EACH OPERATOR IF MORE THAN
ONE OPERATOR IS USED ON A PRESS.  PART INSPECTED APPLIED TO EACH DEVICE.

       NOT                                                   DATE OF
 OK    OK    PART INSPECTED      IF NOT OK, CONDITIONS     CORRECTION

____  ____   All parts, nuts, 
             bolts,etc. secure _________________________   ____________

____  ____   Attachments connected 
             to and being operated 
             only by the press slide 
             or upper die ______________________________   ____________

____  ____   Attachments adjusted to
             prevent each operator
             from reaching into the point
             of operation or to withdraw
             the operator's hands from the 
             point of operation before the
             die closes ________________________________   ____________

____  ____   Horizontal support 
             Secure ____________________________________   ____________

____  ____   Vertical support 
             secure ____________________________________   ____________

____  ____   Cables must not be
             bent,frayed or twisted ____________________   ____________

____  ____   Brackets secure and in good
             condition _________________________________   ____________

____  ____   Visual inspection 
             of total system ___________________________   ____________

I, the undersigned, certify that on this date and time, I followed the
above inspection procedure on the indicated machine and found the 
device/devices in good operating condition and properly  adjusted to 
ensure the safe operation of the press by the operator/operators.

Signature _____________________________________________________________
                      (Name and Job Title)

PULL-OUTS APPROVED FOR OPERATION ______________________________________
RED TAGGED _____________________




Appendix E: Sample employer self-inspection checklist
safeguards and other hazards

Answers to the following questions should help the interested reader to determine the safeguarding needs of his or her own workplace, by drawing attention to hazardous conditions or practices requiring corrections.

Requirements for All Safeguards

1. Do the safeguards provided meet the minimum OSHA requirements?

2. Do the safeguards prevent workers' hands, arms, and other body parts from making contact with dangerous moving parts?

3. Are the safeguards firmly secured and not easily removable?

4. Do the safeguards ensure that no objects will fall into the moving parts?

5. Do the safeguards permit safe, comfortable, and relatively easy operation of the machine?

6. Can the machine be oiled without removing the safeguard?

7. Is there a system for shutting down the machinery before safeguards are removed?

8. Can the existing safeguards be improved?

Mechanical Hazards

The Point of operation:

1. Is there a point-of-operation safeguard provided for the machine?

2. Does it keep the operator's hands, fingers, body out of the danger area?

3. Is there evidence that the safeguards have been tampered with or removed?

4. Could you suggest a more practical, effective safeguard

5. Could changes be made on the machine to eliminate the point-of operation hazard entirely?

Power transmission apparatus:

1. Are there any unguarded gears, sprockets, pulleys, or flywheels on the apparatus?

2. Are there any exposed belts or chain drives?

3. Are there any exposed set screws, key ways, collars, etc.?

4. Are starting and stopping controls within easy reach of the operator?

5. If there is more than one operator, are separate controls provided?

Other moving parts:

1. Are safeguards provided for all hazardous moving parts of the machine, including auxiliary parts?

Nonmechanical Hazards

1. Have appropriate measures been taken to safeguard workers against noise hazards?

2. Have special guards, enclosures, or personal protective equipment been provided, where necessary, to protect workers from exposure to harmful substances used in machine operation?

Electrical Hazards

1. Is the machine installed in accordance with National Fire Protection Association and National Electrical Code requirements?

2. Are there loose conduit fittings?

3. Is the machine properly grounded?

4. Is the power supply correctly fused and protected?

5. Do workers occasionally receive minor shocks while operating any of the machines?



Appendix F: Sample Report - MECHANICAL POWER PRESS
POINT OF OPERATION INJURY REPORT (1910.217(g))

OSHA RECORDABLE CASES
EMPLOYER

Name __________________________________________________________________
_______________________________________________________________________

Address________________________________________________________________
______________ Zip_____________________________________________________

Injured Employee

Name___________________________________________________________________

Description of Injury__________________________________________________
_______________________________________________________________________

Date of Injury_________________________________________________________
_______________________________________________________________________

Task Being Performed___________________________________________________
_______________________________________________________________________
       (Operation, Set-Up, Maintenance or Others-Be Specific)

PRESS DESCRIPTION

Type of Press Clutch___________________________________________________
_______________________________________________________________________
       (Full Revolution, Part Revolution or Direct Drive)

Type of Safeguards Being Used__________________________________________
_______________________________________________________________________
(2-Hand Control, 2-Hand Trip, Fixed Barrier Guard, Adjustable Barrier 
Guard, Type "A" Gate or Movable Barrier Guard, Type "B" Gate or Movable
Barrier Guard, Presence Sensing Device, "Radio or Light Wave", Pull 
Outs, Restraints, Hold Outs, etc.)

ACCIDENT CAUSE

Cause of Accident______________________________________________________
_______________________________________________________________________
(Repeat of Press, Safeguard Failure, Removing Stock Part of Scrap, No 
Safeguard Provided, Safeguard Provided but not Being Used, Incorrect 
Control Mode Used or Other, Improper Usage or Adjustment-Be Specific)

MACHINE LOADING

Type of Feeding________________________________________________________
_______________________________________________________________________
(Manual With Hands in Die or With Hands Out of Dies, With Hand Tools, 
Semi-Automatic or Others-Be Specified)

PRESS ACTUATION

Means Used to Actuate Press Stroke_____________________________________
_______________________________________________________________________
(Foot Trip, Foot Control, Hand Trip, Hand Control or Other-Be Specific)

OPERATORS

Number of Personnel Required for Operation_____________________________

Number of Operators Provided with Controls and Safeguards______________

DATE OF REPORT_________________________________________________________

PREPARED BY____________________________________________________________

OFFICIAL POSITION______________________________________________________
_______________________________________________________________________




APPENDIX G: MECHANICAL POWER PRESSES
QUESTIONS AND ANSWERS


Page
I.Scope of the Standard2
II.Control Systems & Brake Monitor3
III.Presence Sensing4
IV.Pull-outs and Sweeps5
V.Two Hand Trips & Controls6
VI.Type A & B Gates8
VII.Barrier Guards & Other Safeguarding9
VIII.Safety Distance12
IX.Record Keeping14
X.Minimum training requirements for power
press operators
15
XI.Minimum training requirements for power
pressroom supervisors
16


NOTE:

Under no circumstances shall the following be used in lieu of the specific language of the law, and final determination of the requirements shall be checked with OSHA. Several questions and answers are referenced according to specific sections of the law in an attempt to provide compliance assistance to interested parties.

(I) SCOPE OF THE STANDARD

1. Q. Does the standard for mechanical power presses cover these presses when other materials are being worked such as nonferrous metals, plastic materials, or other materials?

A. The Section 1910.217 requirements do not contain a statement of scope and application at present. The intent of OSHA is to honor the scope as stated in ANSI B11.1-1971 which was adopted under Section 6 (a) of the Act. B11.1-1971 scope statement covers presses used to cut, form, ... "other materials" when the die is attached to the slide. B11.1 also covers the use of unitized tooling. The use of the mechanical power press to work on aluminum, tile, or non-ferrous metals hardly changes the need for operator safeguarding based on the material being processed.

2. Q. Are press brakes covered by the standard for mechanical power presses?

A. No.

3. Q. If a press brake is fitted with dies and functions as a mechanical power press, is safeguarding required?

A. Yes.

4. Q. What type of presses or other metal working machines are exempt from Section 1910.217?

A. Some types of presses not covered by 1910.217 are envelope making (window cutters, etc.) machines, dinkers and clickers used for cutting leather and other materials, brick presses, broaching machines, abrasive wheel presses, platen presses, powdered metal presses, hot bending and forming machines, forging presses.

5. Q. Are hot bending operations covered by Section 1910.217(a)(5)?

A. No.

(II) CONTROL SYSTEM & BRAKE MONITOR

6. Q. For ungrounded circuits, is the first ground considered a failure?

A. No.

7. Q. When operating on continuous run, is a single failure in the press control system required to stop the press?

A. No, it prevents a successive continuous run being initiated.

8. Q. If a press is only operated on continuous, must a single stroke mechanism be provided?

1910.217(b)(3)

1910.217(b)(7)(xi)

A. No.

9. Q. If a press stroke cannot be initiated because of the brake monitor action, how is this indicated to the operator?

A. The control system may have an indicator light or alarm. The visual inspection of markings on the crankshaft will show that press slide has not stopped within the safe range previously established. The press won't run.

10. Q. If the brake monitor is actuated by top stop overrun, can the brake initiation point be set earlier in the cycle if the safety distance is recalculated and two-hand controls moved?

A. Yes, this practice is allowed as long as the brake is deemed to be functioning within its stopping time limit before overhaul and repairs are required.

11. Q. If a press stops at some point of the cycle due to the brake monitor, how is the press slide returned to top of stroke?

A. The inch controls or other bypass circuit are used to return press slide to top of stroke.

12. Q. Must brake monitors detect brake deterioration when the brake is applied at other than top of stroke?

A. No, but some types of brake monitor will give an indication of stopping time on each brake application at any point in the stroke.

13. Q. Can a press be operated on-the-hop with a brake monitor?

A. No, the press slide must stop on each stroke for the brake monitor to be effective.

14. Q. Is a brake monitor necessary on a full revolution clutch press?

A. A brake monitor is not required on a full revolution clutch press. Brake monitor manufactures and users are claiming that they are feasible and useful on a full revolution clutch press.

(III) PRESENCE SENSING

15. Q. Do presence sensing devices require some form of additional guarding to protect press operators?

A. Yes, unless the sensing field covers all paths of access to the point of operations; therefore, some additional safeguarding is required such as fixed barrier guard, Type A or B gate or movable barrier device, or another presence sensing device.

16. Q. What are the limits of muting of a presence sensing device to enable parts ejection, feeding, or circuit checking?

A. Top of stroke is the point at which muting shall cease as it is not possible to set a point on the downstroke at the exact position where the hazard of die closing starts.

IV. PULL-OUTS & SWEEPS

17. Q. Are pull-outs acceptable for safeguarding the press operator when press stroke is actuated by a foot pedal or a two-hand trip not meeting the required safety distance?

A. Yes, the pull-outs by themselves are recognized as an acceptable safeguard.

18. Q. Why are detailed requirements given for checking and adjusting of pull-outs?

1910.217(c)(3)(iv)(d)

A. Pull-outs are a more personal form of safeguard whose proper functioning can be affected when operators are changed, or a new die set for operation. Visual inspection of pull-outs can detect wear of parts as well as proper action when press is stroking.

19. Q. Can a restraint be used for "hands in dies" feeding?

A. No. By definition the restraint does not permit entry of the hand into the die or point of operation.

20. Q. Can a restraint used for one hand be used in conjunction with a single trip or control button for the second hand, where the second hand is used for feeding into the point of operation?

A. Yes, if a safety distance is established for the one-hand trip or control button.

21. Q. What is the difference between a restraint and a pull-out device?

A. The restraint prevents entry of hands or fingers to the point of operation at all times, while the pull-out device will allow hands in dies for feeding.

22. Q. Are restraints or hold-outs a recognized form of safeguarding from the hazard of the point of operation?

A. Yes, the restraints which keep operators' hands out of the point of operation at all times are an acceptable safeguard.

23. Q. Are two-hand trips recognized as an acceptable means of safeguarding the operator from the hazard of the point of operation?

A. Yes, providing the safety distance between the point of operation and the two-hand trips is determined by the appropriate formula.


V.TWO HAND TRIPS & CONTROLS

24. Q. What are some of the methods or means used to fix the position of two-hand trips or controls at the safety distance?

A. Articulating or extendable bars or control mounts, clearly established floor position for portable control stands, or other administrative controls may be used when it is not possible to mechanically or electrically fix the portable stand or station in position.

25. Q. Can a two-hand trip be used as a safeguard on a part revolution clutch press?

A. Yes, providing the safety distance for locating the trips is adequate.

26. Q. What methods are used to fix the position of two-hand trips or controls?

A. Key-locked control stations, key-locked portable control stands, removable plug-in control stations, portable stand floor location fittings, portable stand bases which establish a safety distance, movable control bars or buttons fixed by fasteners which require the use of special tools to remove.

27. Q. Can a two-hand control be used as a trip on a part revolution clutch press?

A. Yes, the holding time is adjustable and could be set to perform like a two-hand trip.

28. Q. On a two-hand control, what "holding time" is required?

A. None, but to qualify as a "control" rather than a "trip" it must be possible to set a "holding time".

29. Q. Must "holding time" cover the entire period of die closing or until the hazard of die closing ceases at 1/4 inch opening?

a. No, holding time can be set for any period of time during the cycle. Press stopping time is the critical factor in establishing the safety distance for safeguarding means.

(VI) TYPE A&B GATES

30. Q. Is a Type A gate an acceptable safeguard with a two-hand trip or two-hand control without adequate safety distance determined by the appropriate formula?

1910.217(c)(3)(I)(e)

A. Yes, the Type A gate alone will satisfy the requirements for safeguarding with any form of press actuation such as foot pedal or control, two-hand trip or control without safety distances, or others such as one-hand trip.

31. Q. Can a Type A gate be opened during the downstroke of the slide?

1910.217(c)(3)(ii)(a)

A. No, a Type A gate remains closed.

32. Q. Can a Type B gate be opened during the downstroke of the slide?

1910.217(c)(3)(I)(g)

A. Yes, on a part revolution clutch press until slide motion ceases.

33. Q. When manual feeding with hands in dies, can a Type B gate or movable barrier device be used for safeguarding on a full revolution clutch press?

A. Yes, the type B gate or movable barrier device which permits manual feeding on the upstroke is an acceptable safeguard.

34. Q. If a Type B gate is used as a means of safeguarding, can a presence sensing light curtain be used to actuate the Type B gate which subsequently initiates the press to work?

A. Yes, the presence sensing light curtain is then only actuating the Type B gate (the operator safeguard).

35. Q. If a Type B gate can be opened during the closing stroke (on a part revolution clutch press), what safety distance is required to be sure slide motion stops before hands reach the point of operation?

1910.217(c)(3)(I)(g) & (c)(3)(ii)(b)

A. A safety distance must be used to insure that the operator's hands cannot reach the point of operation prior to die closing or reaching a point (1/4 inch die opening) where no hazard of die closing exists.

(VII) BARRIER GUARDS & OTHER SAFEGUARDS

36. Q. Can an interlocked barrier guard be installed on a press for protection of an operator manually feeding strip stock through openings in the side or through the movable section of the interlocked barrier guard?

1910.217(c)(2)(iv) / 1910.217(c)(2)(v) / 1910.217(c)(2)(vi)

A. Yes, this form of guard may be used; however, the hinged or movable section must be interlocked and can only be opened for clearing a jam or piece of scrap or die changing when the machine has stopped.

37. Q. Can "redundant" or "alternative safeguarding" prescribed by the latest draft ANSI B11.1 revised standard be used in lieu of the OSHA 1910.217(c)(5) "Additional Safeguarding" requirements for part revolution clutch presses (using two-hand control, presence moving or Type B gate of movable barrier device)?

A. Yes, providing a variance has been granted by OSHA under Part 1905 regulations. The approval of the revised ANSI B11.1-1975 standard may warrant a future proposed amendment to grant acceptance to the option of "alternative safeguarding" under OSHA standards. All new or improved means of safeguarding will be subject to future OSHA proposals to bring new technology on stream as soon as proven.

38. Q. Does the use of handtools for feeding qualify as a "hands out of dies" operation?

A. Yes.

39. Q. Is compliance with paragraphs (b)(13) and (b)(14) required when handtools are used for feeding?

1910.217(c)(4) / 1910.217(c)(5)

A. No.

40. Q. If presses are operated with "hands out of dies" feeding methods, must safeguarding be provided?

A. Yes.

41. Q. Why?

A. The "hands out of dies" requirement can only be achieved when some form of operator safeguarding is utilized. Handtool feeding, while qualifying as a "hands out of dies" procedure, along with the sliding bolster feeding method, in and of themselves, do not insure that the operator cannot get his hands in the die. These approaches should be used in conjunction with other safety devices; e.g. two-hand trip, Type A and B gates, presence sensing, etc.

42. Q. On presses operated as a "hands out of dies" for feeding must the applicable construction requirements of paragraph (b) be met?

A. Yes.

43. Q. For controls, foot pedals and controls, brakes and safeguard devices?

A. Yes, the standard as promulgated makes no distinction for presses used for "hands out of die" feeding. It is conceivable that a claim can be made that no operator hazard is present on "hands out of dies" operations; therefore, construction requirements need not to be met to insure employer protection from "recognized hazards". The argument, of course, fails on a change to "hands in dies" for a subsequent run. How can a press be reserved exclusively for "hands out of dies" operation and possibly receive a variance?

44. Q. Why are tools required for removal of scrap or stuck work pieces when hand feeding is allowed?

A. Removal and clearing operations are not considered to be as technically difficult as the feeding of dies. The requirement will reduce the number of times that the operator's hands are in the dies and represents a compromise with the former rule for no hands in dies at all times.

45. Q. Can the press control reliability requirement of 1910.217(b)(13) be met on a full revolution clutch press?

A. It is not required on a full revolution clutch press. Claims are being made that such a control criterion can be met on a full revolution clutch press.

46. Q. The new requirements for testing of clutch/brake mechanism, anti-repeat feature, and single stroke mechanism appear to apply to those presses operated on single stroke with "hands in dies" feeding only?

1910.217(c)(5)-Additional requirements for safeguarding

A. The only presses excepted from the rule are those that comply with paragraph (c)(5)covering control systems in paragraph (b)(13) and brake monitoring in paragraph (b)(14).

47. Q. Is a sliding bolster by itself recognized as an acceptable safeguard?

A. No.

48. Q. If a sliding bolster is used to feed parts, are two-hand controls required to meet the safety distance requirements?

A. Yes.

(VIII) SAFETY DISTANCE

49. Q. Where is the safety distance measurement taken from? The die or the edge of the bolster or slide?

A. The safety distance is measured from the point of operation of the die (a recognized hazard). The die dimensions may be less than or greater than the size of the slide or bolster.

50. Q. There are different formulas for calculating the safety distance on part revolution clutch machines using two hand control and full revolution clutch machines using two hand trips. What is the significance of the sub letters Ds, Dm, Ts, and Tm?

A. Different sub letters are used to aid users in recognizing that two separate formulas are used for calculating safety distance depending on the type of clutch.

51. Q. When the safety distance is calculated using the formula, what amount of supplemental distance (margin) is required to determine the point at which controls or trips are located?

A. None; however, it is expected that an additional (margin) distance will be added to allow for some brake stopping time deterioration or slide stopping point tolerance.

52. Q. What is "separation"? What is "safety distance"? Are they the same?

A. "Safety distance" is the proper distance from the controls to the point of operation, as defined in ANSI B11.1-1982, -1988, and the 1994 ANSI draft proposal of April 24, 1994. "Separation" is the term used in ANSI B11.1-1982, -1988, and the April 24, 1994 draft revision, which compares with the term "separation" OSHA uses to refer to the distance between an operator's hand controls to require the use of both hands to operate the press.

53. Q. What is meant by separation when describing the position or arrangement of two hand trips and two-hand controls?

OSHA recognizes the use of "separation distance" when applied to locating two-hand control buttons remote from each other to discourage attempts at one-hand actuation.

54. Q. What is the source of the 63" hand speed constant?

A. European studies by Dr. O. Lobl of Sweden which determined a safety distance for use in the regulations of foreign countries.

55. Q. Which formula is proper for finding the safety distance on a part revolution clutch press with two-hand controls?

1910.217(c)(3)(vii)(c)

No formula for calculating safety distance on a part revolution clutch press actuated by a two-hand trip is provided. The time recommended would be that for the die closing stroke.

56. Q. Why is the position of approximately 900 of crankshaft rotation chosen for determining brake stopping time?

The longest possible stopping time should be used when calculating the safety distance. The point in the stroke near point of maximum speed or half way down was considered to be the best place to measure the longest time for stopping the slide. This conclusion is currently being challenged based on testing by several people.

(IX) RECORD KEEPING

57. Q. How long must the records required by Section 1910.217(e) be kept?

A. Section 1910.217(e) makes no provision for record retention period.

58. Q. Are Federal agencies required to report injuries to press operators?

A. No.

59. Q. Must a written record be kept of pull-out adjustment and testing for each shift change, operator change, or new die set-up?

1910.217 (c)(3)(iv)(d)

A. The record keeping requirements of 1910.217(e) are applicable.

60. Q. If an employee is injured by a broken piece/part thrown from the die, must a report be sent to the OSHA Directorate of Safety Standards?

A. No, only injuries to employees which occur within the point of operation are to be reported.

61. Q. Where did the weekly period for inspections come from?

A. ANSI B11.1-1971 explanatory column accompanying requirements for inspections.

62. Q. What periods are recommended by the ANSI B11.1-1971 for press inspections?

A. B11.1-1971 recommended weekly, monthly, or possibly longer periods for press and safeguarding inspections, testing, and maintenance.

63. Q. Are records required to be kept?

A. Yes, B11.1 requires records of inspections.

64. Q. For how long?

A. No definite retention periods are prescribed by OSHA for power press records.

65. Q. Are periodic inspections and records required for all presses even when operated on continuous or with no hands in dies?

A. Yes, every press is required to be inspected and maintained to protect the safety of operators, die setters, and others.

66. Q. Is it necessary to report minor injuries such as a scratch or pinched finger when feeding a die?

A. No, only report those injuries which qualify for listing on the OSHA Form 200.

(X) MINIMUM REQUIREMENTS FOR POWER PRESS OPERATORS TRAINING

The operators of mechanical power presses must be trained in all phases of the operation of the equipment and its capabilities and limitations, and:

A. All press controls and how to use them.

B. The operator must be informed of the safety guards and devices incorporated on the machine and the correct use of each.

C. Each operator must be instructed in the use of tools for removing stuck work and the use of swabs, brushes, or oil cans for lubricating dies and stock.

D. Press operators will need to understand why, when, and how to use personal protective equipment, such as safety glasses, gloves, safety shoes, and hearing protection.

E. The storage of parts, tools, or other objects on dies, die sets, bolster plates, or press components not designed to retain them; present hazards of falling on operators; and possible pinch points with moving components. Operators must be aware of these hazards, as well as the basic housekeeping around the press areas.

F. Press operators must be instructed not to operate the press until the press has been checked and tested several times prior to production operations. He/she should report any problems which he/she observes to the proper person.

G. Employees who are going to operate presses must receive a minimum of 8 hours* on the job training under supervision prior to being assigned to operate the presses. *this could be up to 2 weeks or more, depending on the complexities of the operation.

(XI) MINIMUM TRAINING REQUIREMENTS FOR PRESSROOM SUPERVISORS

A. The foreperson must be informed of his responsibilities to the employer and the employees who work with him/her.

B. He/she must know the hazards of power press operations and their set-up and maintenance.

C. The pressroom foreperson must be knowledgeable of what the safety guards and devices are intended to do and the correct adjustments and use of each.

D. He/she must check each set-up and be sure that all operators are instructed in safe power press operations before they start work.

E. It is his/her responsibility to insure that correct operating procedures are being followed.

F. The foreperson must see that all maintenance is performed and that presses are in safe repair prior to their operation. As the employer's representative, the pressroom supervisor is responsible for the training and operations of the employees under his/her control.
Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.