In pre-rule notice in its Fall 2018 Unified Agenda , OSHA indicates that it would like to update the public record on a 2007 advanced notice of proposed rulemaking (ANPRM) to revise its existing (1971) standard governing mechanical power presses (29 Code of Federal Regulations (CFR) 1910.217). OSHA notes in the Agenda that the current standard does not reflect technological changes. While the ANPRM is itself more than 10 years old, the worker protection options it describes would be a substantial safety advance over the protections required in the existing standard.
Danger Zone
The mechanical power press standard contains provisions for safeguarding the point of operation of the press, the area of the press between the punches and the die block. These requirements help ensure that employees are clear of this danger zone when the press is in operation. The standard requires employers to ensure the use of point-of-operation guards or properly applied and adjusted point-of-operation devices on every operation performed on a mechanical power press. Under the standard, employers can utilize a number of different types of guard systems.
Presence-Sensing Devices
Among its gaps, 29 CFR 1910.217 does not cover hydraulic and pneumatic power presses and also does not consider the use of presence-sensing-device initiation (PSDI) systems. When a press is equipped with PSDI, the cycle will not initiate until the PSDI system senses that the danger zone is clear. In 1988, OSHA updated the mechanical power presses standard to permit the use of PSDI systems. However, the rule requires an OSHA-approved third party to validate the PSDI system at installation and annually thereafter. “Since the adoption of this provision, no third party has sought OSHA’s approval,” OSHA reported in 2007. “Consequently, PSDI systems are not being used with mechanical power presses.”
Correlation with ANSI
In the 2007 ANPRM, OSHA solicited comments on the following potential revisions to the 1971 standard and other considerations:
- Change the scope of the standard to include other types of power presses, such as hydraulic presses and pneumatic presses. OSHA also requested feedback on whether there are other newer types of power presses that should be included in a revision.
- Whether a revision should be based on the American National Standards Institute’s (ANSI) 2001 Mechanical Power Press standard (B11.1). ANSI revised this standard in 2009.
- Whether the use of computer technology has affected the safety of power presses.
- Should OSHA retain the third-party PSDI validation requirement?
- OSHA’s current PSDI provisions include requirements for brakes and clutches that are not found in ANSI B11.1-2001. OSHA asked if it should retain these or similar requirements in a revised standard?
- OSHA currently limits PSDI systems to normal production operations (and not die-setting or maintenance procedures). Should OSHA continue this limitation?
- What additional costs have been involved in integrating PSDI systems into manufacturing operations? What have been the benefits in terms of safety and productivity?
- OSHA’s current standard requires employers to train employees on safe methods of work. However, the standard does not spell out specific training or retraining requirements. Should OSHA change its existing performance-oriented approach with specific training and retraining provisions?
- ANSI B11.1–2001 specifies that an inspection program be established with regular inspection of presses but does not specify the time frames for such inspections. Also, B11.1-2001 does not specify the information employers should maintain in inspection records. Should OSHA adopt ANSI’s performance-oriented approach in a revised standard?
As noted, ANSI revised its power press standard in 2009, and these revisions may alter some of the questions OSHA posed in 2007 should the Agency decide to issue a revised ANPRM.