b'Technical & Research Committeeoff no go areas in our sheet metal fabrication shop redesignStandard machine access limiting techniques should be currently underway. used.Absolute Safety Standards if a Fault Developed Watch for Safety ImprovementsWeve also tightened up our existing policy that a machineMembersshouldperiodicallyasktheirmachines cannot be used for production if it has a fault.By tighteningmanufacturer if there are any safety upgrades/updates up our lock-out and key control weve moved an intent to anavailable.We do this at each annual service.absolute.Only service techs or our own people under theVerify and Document your Programdirection of service techs are allowed to energize a machine that has developed a fault. Every robust program stands up to being examined and Summary of Recommendations for Safer Operations verified.Notingthatadd-onsystemsareunavailable,mayonlyMembersshouldperiodicallyrevisittheirprogram, partially mitigate risks if they were, have false positives andcheck their training records, and document that they did missed positive issues, are often bypassed as a result, anda program health check.in that the end still completely depend on operator trainingAPPLICATION TO OTHER MACHINES AND RISKSand discipline, weve returned to absolute basics: Tread carefullyTrain, Train, Train While the principles and research direction we took for our Control Access, including locking the machines out projectmayseemtodirectlyapplytoresearchingother Strict procedures in addressing any machine faults safety concerns, tread carefully.Continued supervisor oversight and gate-keeper control Sorting through the OSHA, ANSI, and other standards is a complex project.Several times deeper research challenged As weve operated these machines for nearly forty years withthe understanding we had gained in initial examination.only the single operators error leading to an injury, wereNot getting things right can lead to unprotected hazards, confident that training and disciple can keep these machinespotentially concealed/masked hazards, and get you cross safe. ways with the regulators.RECOMMENDATIONS TO MEMBERS Use ExpertsDocument your Training It is best to consult and at times subcontract research to First recommendation to Members is to document yourexperts.We used the legal professionals affiliated with our training.If you have any holes, get that training caughtassociation, an impartial hired safety professional engineer, up.If you havent any formal safety training for youran international safety sensor manufacturer, and did small machine see if you can get the manufacturer to help youconsultations with a half dozen other safety firms.We also with training.lookedtoourmachinesmanufacturerforsomesupport As a minimum every operator, and anyone supervisingand developed a fruitful working relationship with our areas or administering access control should be safety trained.OSHA team.Consider periodic retraining. Be aware that in the case of the machine manufacturer their position needs to center on supporting the safety, training Asareminderforsignatorymembersyoumayhaveand regulatory posture they are bringing to the market, and trainingfundsavailablethatcanoffsetsomeofyourthey may not be able to respond with as much detail as one training costs. might like.Take control of Machine Access Also, the OSHA team will be incorporating their organizational Second thrust is to limit operator access only those youstance,prettymuchhastogeneralizeormakegeneric have trained and approved. suggestions,andthatOSHAneverapprovesanything- Usethemachinekeyandimplementlock-outoftherather they basically stop disapproving of solutions that meet power. their regulatory and safety goals.If your shop is large enough to have control issues, youHave someone else take a look at your workmay want to log keys & operators, but that would seemIt is also worthwhile having someone else look over your silly in a small shop. findings.In our case we went back to our hired professionals, Mark Off and Control Access to Machine Space our counsel, and to OSHA in a candid discussion to review our findings.Not only does this work towards achieving By marking off and controlling access to machine spaceconsensus among the parties, it is reassuring that others you can reduce any potential for a non-operator beingcome to the same conclusions when back-checking your too close to the machine. work. www.mrca.orgMidwest Roofer 39'