- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
April 7, 2004
Senior Director, Federal Policy
Printing Industries of America, Inc.
100 Daingerfield Road
Alexandria, Virginia 22314-2888
Dear Ms. Lechner:
Thank you for your October 25, 2002 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. Your letter raises issues discussed during an October 4, 2002 conference call and contained in previous letters to OSHA. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to scenarios or questions not delineated in your correspondence.
Your letter raises specific questions regarding the application of the Control of hazardous energy (lockout/tagout) standard, 29 CFR 1910.147, in the printing industry. This response will comment on OSHA's September 16, 1992 letter to John Runyan and the June 14, 1993 follow-up memorandum to OSHA Regional Administrators. This background, your questions, and our replies follow.
Application of the Lockout/Tagout Standard. The lockout/tagout standard applies to servicing and maintenance performed on numerous machines and pieces of equipment in an array of industries, including the printing industry. Servicing and maintenance activities are necessary adjuncts to the industrial process, enabling machines or equipment to perform their intended functions. The core of the lockout/tagout standard, which permits employees to work on machines or equipment safely, is the shutdown and de-energization of machinery and the isolation of energy source(s), which is accomplished through the application of hazardous energy control measures. This normally consists of stopping the machine or equipment, isolating it from its energy source(s), locking or tagging out the energy isolating devices, releasing or relieving stored or residual energy, and verifying that the machine or equipment is safe to work on. All energy control activities must be conducted in accordance with procedures developed, and in most cases documented, by the employer for the purpose of controlling hazardous energy.
In promulgating the standard, OSHA recognized circumstances in which servicing and maintenance activities would be performed (in full or in part) without locking or tagging out the machinery or equipment. One such circumstance is detailed in §1910.147(f)(1), which recognizes that lockout/tagout devices must be temporarily removed in limited situations to permit testing or repositioning and establishes procedural steps to maintain the integrity of any lockout/tagout program.
Another such circumstance is detailed in the exception to 1910.147(a)(2)(ii) and is referred to as the minor servicing exception. OSHA recognized that, "if the servicing operation is routine, repetitive, and must be performed as an integral part of the production process, lockout or tagout may not be necessary because these procedures would prevent the machine from economically being used in production." 54 FR 36644, 36662 (September 1, 1989), as amended at, 55 FR 38677, 38679 (September 20, 1990). Thus, the Agency adopted the minor servicing exception.1 The exception provides that:
Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).
It is important to note that the lockout/tagout standard applies only if workers are exposed to hazardous energy during servicing and maintenance activities. The lockout/tagout standard complements the requirements for machine safety prescribed by various general industry standards in 29 CFR Part 1910, and an employer may avoid the requirements of the lockout/tagout standard, if the employer protects employees from exposure to hazards throughout the servicing and maintenance process by using machine guarding in accordance with the Machine Guarding requirements of 29 CFR Part 1910, Subpart O. In other circumstances, such as during some machine set-up operations, it is necessary to supplement lockout/tagout procedures with machine guarding (a.k.a. safeguarding [barrier guards, safeguarding devices]) methods to adequately protect employees from the hazardous energy.2
OSHA's September 16, 1992 letter. The printing industry has posed questions over time regarding the application of the lockout/tagout standard, particularly the application of the minor servicing exception. OSHA explained in a September 16, 1992 letter to John Runyan that the machine guarding standards apply to normal production operations, while the lockout/tagout standard applies during servicing or maintenance activities. The lockout/tagout standard applies whenever employees engaged in servicing or maintenance bypass guards or otherwise become exposed to hazardous energy; if employees performing servicing or maintenance are not exposed to hazardous energy, the standard does not apply.
The following tasks were identified in the September 16 letter as examples of minor servicing activities commonly performed (during normal production operations) in the printing industry: a) clearing certain types of paper jams; b) minor cleaning, lubricating, and adjusting operations; c) certain plate and blanket changing tasks; and, d) in some cases, paper webbing and paper roll changing. The letter also provided that the inch-safe-service technique used in conjunction with the main drive control appeared to provide effective alternative protection for these minor servicing activities.3 The letter further recognized that this technique was consistent with the use of controls specified in the American National Standard Institute (ANSI) standards B65.1 (1985) and B65.2 (1988) for web- and sheet-fed printing presses for which, as a minimum, a stop/safe/ready function must be available at the designated control stations.4
As emphasized above, the September 16 letter did not state that all un-jamming, cleaning lubricating, adjusting, plate/blanket changing, and paper webbing/paper roll changing operations in the printing industry were subject to the minor servicing exception. As previously described, employers can use effective alternatives to lockout/tagout only in the limited circumstances outlined in the 1910.147(a)(2)(ii) exception.5 Thus, for example, a normal blade changing operation on a guillotine paper cutter would not qualify for the minor servicing exception because, among other things, the activity is performed infrequently and cannot be done while the machine is operating in a production mode. This task would need to be performed pursuant to an energy control procedure that specified the lockout/tagout steps and any machine guarding methods necessary to control employee exposure to hazardous energy associated with the cutter.6
Response to your letter. Your letter poses three questions; our replies follow:\
Question #1: The June 14, 1993 memo to OSHA Regional Administrators, regarding the Applicability of the machine guarding and lockout/tagout standards to printing presses, has been interpreted as not recognizing the inch-safe-service technique as alternative, equivalent protection for some pieces of equipment. The existing clarification does not define a "printing press," and therefore, some have concluded that the inch-safe-service technique could not be used for minor servicing activities on binding and finishing systems. However, some printing presses have integrated cutting, folding, and delivery devices. For purposes of the OSHA lockout/tagout standard, what is the definition of a "printing press"?
Reply: The lockout/tagout standard does not define a "printing press," as the standard addresses generally the servicing and maintenance of equipment and machinery. However, the interpretive guidance and policy contained in OSHA letters, compliance directives, and relevant Federal Registers may address specific machines or pieces of equipment. Ultimately, in every case, employers must analyze alternative methods in light of the functions and operations of the specific machinery, and employers can use an alternative method only if it effectively protects employees from exposure to hazards otherwise incumbent with the servicing and maintenance activities.
In response to input received after issuing the September 16 letter, OSHA issued a memorandum on June 14, 1993. The memorandum explained that the September 16 letter provided guidance only with respect to effective alternative protection for minor servicing activities in conjunction with printing processes. From your letter, it appears that the June 14 memorandum has been interpreted to state that the inch-safe-service technique does not constitute effective alternative protection for minor servicing activities performed on binding and finishing systems -- such an interpretation is incorrect. Rather, the memorandum merely reserved the question of whether the inch-safe-service technique could provide effective alternative protection during minor servicing performed on binding and finishing systems. As detailed in our reply to your next question, OSHA has considered minor servicing performed on binding and finishing systems and concluded that the inch-safe-service technique may be used to provide effective alternative protection.
Question #2: Is the inch-safe-service technique, which is used in conjunction with equipment meeting the appropriate ANSI standard for binding and finishing equipment, an acceptable form of alternative equivalent protection for minor servicing activities?
Reply: The inch-safe-service technique described in this letter and detailed further in the September 16 letter to John Runyan, may be used as alternative effective protection for minor servicing activities associated with binding and finishing equipment with appropriate control systems described in ANSI B65.2.7 The following summarizes the essential elements of the inch-safe-service technique, including the safeguarding practices:
- Servicing or maintenance must not be conducted when machine components are moving. Before performing any minor servicing, the machine must be STOPPED, and its drive control must be in STOP/SAFE position.
- Consistent with the provisions contained in 1910.147(f)(1), procedures to INCH a machine must include a pre-startup check to assure the safe positioning of employees and to assure that all tools, etc. are positioned so that they do not create a hazard for employees.
- DEACTIVATE the SAFE function immediately before safely inching the machine component for positioning purposes -- a procedural element implicit in the September 16 letter.
- By use of the INCH control, the components of the machine are moved to their desired position. Immediately thereafter, the drive control is placed on STOP/SAFE by each employee working in a hazardous area before beginning or resuming the minor servicing work activity.
- Steps (2) through (4) are repeated as necessary until the minor servicing is completed.
Question #3: May employers utilize a combination of appropriate machine guarding techniques as specified by ANSI B65.1 and safe work practices as an alternative form of equivalent protection during the performance of a minor cleaning operation called "blanket washing" while the press is energized? This approach would be in addition to the inch-safe-service method with presses meeting the ANSI B65.1 provisions.
Reply: OSHA permits the use of ANSI standards to abate a hazard, as long as the ANSI standard provides a level of protection that is equal to, or greater than, relevant OSHA standards. With regard to blanket washing, and as described above, compliance with the Machine Guarding, 29 CFR Subpart O, standards can provide an acceptable alternative to lockout/tagout by preventing exposure to hazardous energy.8
It is OSHA's understanding that, in some instances, employees in the printing industry perform blanket-cleaning operations on the out-running side of an offset printing press while the machine is operated in a "slow run" mode. The press operators use folded towels (containing solvent), which are held in the palm of a hand (so that no loose ends are available), to clean the moving cylinders. These slow moving cylinders have smooth surfaces (e.g., without projection, gaps, notches or other surface features that may grab a towel or otherwise cause injury to workers) that pose no additional hazards during the hand cleaning task. Additionally, if employees are exposed to nip points on the in-running side of the press, barrier guards that fully extend across the entire smooth surface of the rolls are used to provide employee protection from all ingoing nip hazards. The barrier guards must meet the requirements of Subpart O and be adjusted to have no more than a one-quarter- (0.25) inch opening at any point between the guard and the printer rolls.9
These described machine-guarding and cleaning techniques prevent employee exposure to hazardous energy while employees perform the roll cleaning; thus, lockout/tagout procedures are not required. However, practices such as reaching around guards, removing guards, and reaching into unguarded danger areas (e.g., to remove a "hickey") defeat the protective value of machine guards, eliminate effective protection during servicing and maintenance activities, and preclude the application of the minor servicing exception. See §1910.147(a)(2)(ii)(A) and (B). Likewise, the lockout/tagout standard applies if employees are exposed to other hazards created by rollers or blankets, such as uneven revolving surfaces or roller/blanket openings or projections. Under no circumstances is an employee ever permitted to place any part of his or her body within a hazardous area, such as a point-of-operation, ingoing nip points, or around power transmission apparatus, while the equipment or machine is running or energized.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed, affirms and builds upon the policy stated in the John Runyan letter, and supercedes any inconsistent prior interpretations on matters contained herein. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.
R. Davis Layne
Deputy Assistant Secretary
1 The minor servicing exception applies only to an activity that must take place during, and is inherent to, normal production operations (i.e., the utilization of a machine for its intended production function) and that is necessary to allow production to proceed without interruption. The minor servicing activity must be:
- Routine: The activity must be performed as part of a regular course of procedure;
- Repetitive: The activity must be repeated regularly as part of the production process or cycle; and
- Integral: The activity must be inherent to, and be performed as part of, the production process.
The exception applies only if the employer provides effective alternative protection from hazardous energy.
Thus, in Westvaco Corp. 16 (BNA) OSHRC 1374 (90-1341, 1993), the Occupational Safety and Health Review Commission (OSHRC) rejected an employer's assertion that set-up activities associated with a printer/slotter machine constituted servicing and maintenance within the scope of the exception. While not reaching the questions of whether the activities were "minor" or whether the alternative protection was effective, the OSHRC concluded that adjustments made while the machine was being set-up according to unique specifications to produce corrugated paperboard containers were not adjustments made during "normal production operations." [back to text]
2 In one example involving a binding and finishing system, a paper trimming device's knife blades reportedly required changing on a monthly basis -- an activity not performed during normal production operations and performed too infrequently to qualify for the minor servicing exception. Based on an informal hazard analysis, it was feasible to change the blade, in accordance with lockout/tagout requirements, by utilizing both the energy control procedures and providing supplemental employee protection during the blade adjustment portion task by using a machine plexi-glass barrier guard (compliant with Subpart O). The transparent guard enabled the operator to adjust the blades using a hand-crank-wheel mechanism when the machine needed to be energized to disengage the clutch mechanism. [back to text]
3 For purposes of the §1910.147(a)(2)(ii) exception, effective alternative protection may not be achieved through the sole use of simple pushbuttons, selector switches, and other control circuit devices, which lack a control logic, such as an interlocked arrangement that provides a single operator with exclusive control over the machinery. [back to text]
4 On presses attended by more than one worker, or when it is possible for one worker to enter the frame or to be obscured from the view of another worker, suitable safety alerting signals or other reliable and effective protective mechanisms also must be employed in conjunction with work procedures and training to achieve effective, alternative protection to lockout/tagout. See Amerisig Southeast, Inc., 1995 WL 49329 (OSHRC) (No. 93-1429, 1995, Spies, ALJ) (without adequate training and procedures, an alarm system was ineffective to prevent one worker from being injured in a nip point, which was created when a second worker, unbeknownst to the first worker, moved the blanket rollers on an offset web press in a reverse direction). [back to text]
5 Alternative measures must enable an employee to perform the minor servicing task without exposure to a hazard. For example, inch buttons, on the inch-safe-service system for printing units on a web-fed printing press, that are located so that an employee can inch the press rolls and simultaneously access the unguarded danger area at the roller's ingoing nip point, would not constitute effective alternative protection. Thus, lockout/tagout provisions would apply in this scenario. See §1910.147(a)(2)(ii)(A) and (B). [back to text]
6 Safeguarding devices, such as presence sensing devices or two-hand control devices, may be used as an integral part of an energy control procedure to protect workers from the hazardous energy whenever locks/tags are removed from energy isolation devices (e.g., the cutter's electrical disconnect source or the power generated clamp's hydraulic safety valve) to test or position components. [back to text]
7 OSHA has not formally considered the application of the ANSI B65 standards in their entirety, and given the significant variety of equipment in the printing industry, it is not possible to state whether application of other methods contemplated in these consensus standards wouldprovide effective alternative protection in every situation. For example, the Additional operating guidelines, contained in section 16 of ANSI B65.2-1999, include the inch-safe-service technique requirements. However, it is not apparent that critical portions of this ANSI standard provide employee protection that is equal to, or greater than, OSHA's standards addressing the control of hazardous energy. Thus, OSHA cannot conclude that compliance with ANSI B65 standards provides effective protection in all cases. OSHA has not adopted the ANSI B65 voluntary consensus standards as OSHA standards or through incorporation by reference within any OSHA standard. [back to text]
8 The OSHA point-of-operation guarding standard, §1910.212(a)(3)(ii), requires that an employer comply with applicable (appropriate) point-of-operation guarding standards published in Part 1910 or incorporated by reference (see §1910.6). In the absence of such applicable standards, which is the case for printing presses, the guarding device must be so designed and constructed so as to prevent (and not merely warn or signal employees of the impending hazard) the operator from having any part of his or her body in the danger zone during the operating cycle. [back to text]
9 After guard installation and prior to the washing operation, the employer needs to verify that the guard is positioned to prevent the operator's hands, clothing, hair, etc. from reaching the machine danger area. The guard opening may need to be further reduced, if the ¼-inch opening is inadequate to fully protect the employee during the cleaning operation. [back to text]