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Compliance with environmental and OSHA regulations are not always easy, as it involves consistent effort to establish and maintain programs to ensure the health and safety of your employees.

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For more information on OSHA standards visit www.osha.gov
or http://bookstore.gpo.gov; for more on ANSI standards visit
http://webstore.ansi.org or www.nssn.org. For more information
from Danray Products call (815) 262-6667, e-mail ryan.ebens@
danrayproducts.com or visit www.danray.com.

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Most moldmaking companies have a toolroom where machine tools are used to make or repair tools and dies.

This toolroom usually has cutting and turning machines like drill presses, milling machines, grinders, lathes and saws. These machines are either manually operated (with or without automatic control) or they are fully automatic. No matter how a machine operates, it very likely creates safety hazards during its operation that could cause serious injury or death to operators or other employees in the machine area. Because employers are required to furnish a workplace free from recognized safety hazards in order to provide a safe working environment in accordance with Section 5(a) of the Williams-Steiger Occupational Safety and Health Act of 1970, there are several safety requirements that must be taken into consideration for cutting and turning machines. The most important safety requirement is safeguarding.

Machine Safeguarding
According to OSHA 29 CFR 1910.212, General Requirements for All Machines, one or more methods of machine safeguarding must be provided to protect the operator and other employees in the machine area from hazards, such as those created by the point of operation, ingoing nip points, rotating parts, flying chips and sparks. Furthermore, the point of operation of machines whose operation exposes an employee to injury must be safeguarded. The safeguard must comply with any appropriate standards or, in the absence of applicable specific standards, must be designed and constructed to prevent the operator from having any part of his or her body in the hazard area during operation of the machine. For cutting and turning machines, a shield is often used for safeguarding. Photo 1 shows a snake-arm shield mounted on a surface grinder.

New warning label that can be affixed directly to bench grinders to remind everyone of the proper adjustments for compliance with OSHA 29 CFR 1910.215.

OSHA has only one specific machine-safeguarding standard that applies to machines commonly found in mold-making toolrooms—29 CFR 1910.215 for abrasive-wheel machinery (grinders). This is one of the most frequently cited standards for violations during OSHA inspections due to improperly adjusted work rests and tongues on bench grinders. According to 29 CFR 1910.215(a)(4), work rests must be kept adjusted closely to the wheel with a maximum opening of 1/8 inch to prevent the workpiece from being jammed between the wheel and the rest, which may cause wheel breakage. In addition, paragraph (b)(9) of this section states that the distance between the wheel periphery and the adjustable tongue or the end of the peripheral member at the top must never exceed 1/4 inch.

Since most people are unaware of these OSHA-required adjustments on bench grinders, a new warning label (see Figure 1) is available that can be affixed directly to bench grinders to remind employers and operators of the proper adjustments for compliance with OSHA 29 CFR 1910.215. This label can help reduce OSHA violations because it clearly depicts a side view of a bench grinder with arrows and large fractions showing the proper adjustments of the work rest and tongue, as well as stating these requirements in the text below. This one-of-a-kind label has been designed in accordance with the ANSI Z535-2002 series of standards for the design, application, and use of labels, colors and symbols for accident prevention.

For all other toolroom machines, the best standards to reference are the ANSI B11 standards for safety on machine tools. This series consists of 24 standards and six technical reports. Unlike OSHA standards, the ANSI B11 standards are continually revised and updated to reflect the current state of the art.

A snake-arm shield mounted on a surface grinder. Images courtesy of Danray Products LLC.

For example, some of the applicable safety standards for manually operated toolroom machines include ANSI B11.6-2001 for manual turning machines (lathes) with or without automatic control, ANSI B11.8-2001 for manual milling, drilling and boring machines with or without automatic control, and ANSI B11.10-2003 for metal-sawing machines. For fully automatic machines, applicable standards include ANSI B11.22-2002 for turning centers and automatic, numerically controlled turning machines, as well as ANSI B11.23-2002 for machining centers and automatic, numerically controlled milling, drilling and boring machines. If perimeter safeguarding is used around a machine or process, the best standard to reference is the ANSI/RIA R15.06-1999 safety standard for industrial robots and robot systems. (RIA is the Robotic Industries Association.) Although the particular application may not be a robot or robot system, this standard provides the most detailed guidelines for the proper implementation of perimeter safeguarding.

Electrical Requirements
In addition to safeguarding, toolroom machinery must comply with several electrical requirements. Although OSHA covers the design of electrical systems in safety standards 29 CFR 1910.302 through 29 CFR 1910.308, the ANSI B11 standards reference a much more comprehensive and up-to-date standard—ANSI/NFPA 79, Electrical Requirements for Industrial Machinery. (NFPA is the National Fire Protection Association.) The 2002 edition is the current edition of this standard; however, a new edition (2006) will be released this year. ANSI/NFPA 79 provides detailed information for the application of electrical/electronic equipment, apparatuses or systems supplied as part of industrial machinery. This standard addresses such issues as requirements for operator controls, emergency-stop devices, disconnect switches, motor starters and protective interlocks.

Another important requirement for toolroom machinery is that all mechanical power-transmission apparatuses such as belts, pulleys, motor shafts, leadscrews and chains must be guarded. OSHA 29 CFR 1910.219 requires everything to be guarded up to a 7-foot level above the floor or working platform. ANSI has its own standard for mechanical power-transmission apparatuses. This standard, ANSI/ASME B15.1-2000, requires that everything be guarded up to 8 feet above the floor or working platform. (ASME is the American Society of Mechanical Engineers.)

Snake-arm lamp.

Electrical dangers such as shock, electrocution and arc flash will always be present on the job, but proper training and safety strategies can minimize the likelihood of injuries and fatalities. OSHA standards 29 CFR 1910.331 through 29 CFR 1910.335 contain safety-related work practices for avoiding the electrical hazards of working on or near exposed, energized parts. Unfortunately, these standards are brief, outdated, and explain only what to do to avoid electrical hazards. A much better standard that is widely used and accepted is the 2004 edition of ANSI/NFPA 70E, Standard for Electrical Safety in the Workplace. This standard explains how to avoid electrical hazards. It covers the full range of electrical safety issues, from work practices to maintenance, special equipment requirements and installation. It even contains requirements for PPE (personal protective equipment) that reflect the latest technology.

Lockout/Tagout
Before servicing or maintaining machines, equipment or processes in which the unexpected release of hazardous energy could cause injury to personnel, certain procedures, techniques, designs or methods must be followed to protect personnel. The unexpected release of hazardous energy includes any unintended motion, energization, start-up or release of stored energy, deliberate or otherwise, from the perspective of the person(s) at risk. The OSHA standard for the control of hazardous energy (lockout/tagout) is 29 CFR 1910.147. However, there is a more comprehensive and up-to-date standard that has been cited in OSHA interpretations and is used by many, if not most, SH&E professionals. This standard is ANSI Z244.1-2003.

Proper Lighting
One general requirement often overlooked in toolrooms is that proper lighting conditions must exist. According to several of the ANSI B11 standards (such as the previously mentioned ANSI B11.6-2001 and ANSI B11.8-2001 standards), lighting must be installed to ensure that personnel can safely perform their tasks. For lighting requirements, the B11 standards reference the ANSI/IESNA RP-7-01 standard, Recommended Practice for Lighting Industrial Facilities. (IESNA is the Illuminating Engineering Society of North America.)

To help industrial users meet applicable ANSI B11-series safety standards as well as the ANSI/IESNA RP-7-01 standard for lighting requirements, snake-arm lamps are available that will light the point of operation of machines or work areas where additional light is required (see Photo 2). The heavy-duty snake arms are made of spring steel covered with vinyl to protect them from grease, oil and contaminants that would weaken their holding ability. They offer practically unlimited adjustment possibilities and long-term holding power. The snake-arm lamps are available with three different mounting styles: direct, C-clamp and magnetic.

Ensuring a Safe Toolroom
When it comes to machine safety in the toolroom, there are many things to consider and many safety standards to reference. Although OSHA has various standards that can be specifically cited for violations during an OSHA inspection (such as 29 CFR 1910.215 for grinders), ANSI provides standards covering the same machines or topics, and these standards are more comprehensive and up to date. Moreover, ANSI has several safety standards for which there is no OSHA equivalent. Therefore, for the safest possible moldmaking toolroom, the best practice is to reference and comply with the latest applicable ANSI safety standards.

For more information on OSHA standards visit www.osha.gov or http://bookstore.gpo.gov; for more on ANSI standards visit http://webstore.ansi.org or www.nssn.org. For more information from Danray Products call (815) 262-6667, e-mail ryan.ebens@danrayproducts.com or visit www.danray.com.