Are you concerned about the possibility of amputations in your facility? Are you in an industry targeted by one of the Occupational Safety and Health Administration’s (OSHA) inspection and enforcement programs?
First, machinery that is not properly locked out or adequately guarded can lead to worker amputations.
Second, OSHA’s enforcement remains strong.
The agency’s rules for lockout/tagout (control of hazardous energy) and machine guarding are among the agency’s most frequently cited standards. The lockout/tagout standard (29 Code of Federal Regulations (CFR) §1910.147) was cited 1,698 times in fiscal year (FY) 2021, and the machine guarding standard (§1910.212) was cited 1,113 times.
The agency has an ongoing National Emphasis Program (NEP) for amputations in manufacturing that was updated in 2019 and is focused on preventing amputations through enforcement of the lockout/tagout and machine guarding standards, as well as the agency’s hand and portable power tools standards (29 CFR 1910, Subpart P).
Industries covered by the NEP include concrete manufacturing; food manufacturing; machinery manufacturing; nonmetallic mineral product manufacturing; paper, pulp, and lumber manufacturing; primary metal and fabricated metal products manufacturing; and plastics manufacturing, as well as furniture and vehicle manufacturing.
Inspection procedures for the amputations NEP include an opening conference to verify with the employer that there is equipment and/or machinery present in the workplace that could cause amputations, followed by a review of incident reports and injury and illness logs and then a workplace walkaround to check for worker exposures to amputation hazards posed by machinery and tools.
During a walkaround, the agency compliance safety and health officer (CSHO) will pay particular attention to employee exposure to cutting actions, nip points, pinch points, shear points, and other points of machine operation.
The CSHO also will evaluate employee exposures during setup and regular operation of the machine, clearing jams or upset conditions, making adjustments while the machine is operating, the cleaning of machines, the oiling or greasing of machines or machine pans, scheduled/unscheduled maintenance, and locking out and/or tagging out.
The agency’s Region 5 office has a Local Emphasis Program (LEP) for food processing facilities in Wisconsin. The outreach, inspection, and enforcement program is aimed at addressing amputation hazards in food manufacturing facilities in the state.
Like the amputations in the manufacturing NEP, the Region 5 LEP also is focused on compliance with the lockout/tagout and machine guarding standards.
From 2014 to 2020, the region’s area offices investigated multiple fatalities, dozens of amputations, fractures, and workers with crushed hands or fingers in the state. Agency inspectors found lockout/tagout or machine guarding violations at the facilities.
The inspection procedures for the LEP are similar to those for the NEP on amputations. Under the LEP, agency CSHOs will evaluate employers’ hazardous energy control programs, including written procedures, authorized and effective training, and the annual periodic inspection of control procedures. During the inspection walkaround, CSHOs will observe worker interaction with food production machinery and evaluate the machinery for any guarding deficiencies that expose employees to catch points, in-running nip points, pinch points, sheer points, or other moving parts.
OSHA’s enforcement of the lockout/tagout and machine guarding standards can result in six-figure fines. Following a series of amputation injuries, OSHA announced citations in June for seven repeat and four serious violations and proposed $190,758 in penalties for a Swainsboro, Georgia, pillow manufacturer.
OSHA conducted an inspection of the facility back in November 2020; following that inspection, three company employees suffered amputations:
- A 22-year-old machine operator suffered an amputation injury in December 2020. During its inspection, OSHA found no lockout/tagout procedures in place to safeguard workers.
- A 40-year-old machine operator experienced an amputated finger and nine crushed fingers in February 2021. The agency found the machine’s energy control locks had been removed.
- A 50-year-old maintenance manager loading a pallet jack onto a truck suffered an amputation after a finger was caught between the wheels of the jack in March 2021.
This June, the agency also announced citations of an Imler, Pennsylvania, metal buildings manufacturer for a willful violation—inadequate machine guarding—after a 40-year-old worker suffered the partial amputation of one finger and an injury to a second one while cleaning a machine at the facility. The company faces $154,143 in proposed penalties.
In addition to the machine guarding violation, OSHA also cited the employer for four serious violations for failing to develop lockout/tagout procedures to prevent unexpected machine start-up, perform an annual review of its lockout/tagout program, and ensure the machine was locked out before workers began cleaning it.
Last year, OSHA cited Tootsie Roll Industries LLC for a willful violation of the machine guarding standard after a 48-year-old worker suffered a partial finger amputation when the employer allowed bypassing safety locks on a machine’s access doors, which led to a bag sealer closing on the employee’s finger. The agency proposed penalties totaling $136,532.
Last August, OSHA cited a Denver milk packaging plant operated by Safeway Inc. with violations of the lockout/tagout, machine guarding, and other standards, proposing penalties totaling $339,379.
The agency inspected the plant after a worker lost four fingers while operating a molding machine that lacked the required safeguards. Deficiencies in the plant’s lockout/tagout compliance included failure to:
- Develop, document, and utilize procedures for the control of potentially hazardous energy.
- Provide locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware for isolating, securing, or blocking machines or equipment.
- Conduct at least annual inspections of energy control (lockout/tagout) procedures to ensure the procedures and the requirements of the standard were followed at the facility.
- Provide adequate training to ensure employees had the knowledge and skills necessary for the safe application, use, and removal of energy control (lockout) devices for several machines at the facility.
OSHA also cited Safeway with a willful, serious machine guarding violation for unguarded machinery that exposed employees to amputation, caught-in/-between, and crushing hazards.
However, OSHA fines for violations can reach seven figures.
Last September, OSHA hit a Ravenna, Ohio, automotive parts manufacturer with $1.6 million in penalties for 38 safety and health violations and placed the employer into the agency’s Severe Violators Enforcement Program following an investigation into a worker’s death.
The employer previously had signed formal settlement agreements with the agency to resolve citations for machine guarding and lockout/tagout violations found during inspections conducted between 2015 and 2017. According to OSHA, a third-party consultant, hired as part of the settlement agreement, identified specific machine guarding and lockout/tagout program deficiencies and made recommendations, but the company failed to fully implement the consultant’s recommendations.
Following the September 2021 inspection, OSHA cited the employer for repeat violations of the lockout/tagout and machine guarding standards.
Specifics of lockout/tagout
The lockout/tagout, or “control of hazardous energy,” standard is aimed at protecting workers from amputation and electrocution hazards, as well as burns and crushed, cut, fractured, or lacerated body parts. Under the standard, employers must develop formal practices and procedures necessary to disable machinery or equipment while it is being serviced or maintained.
The standard requires providing safety instruction for all employees who work in an area where lockout/tagout procedures are utilized. Instruction must include the purpose and use of the energy control procedures. An employer must make employees aware of the standard’s prohibition against restarting or reenergizing machines or equipment that has been locked or tagged out.
Employees authorized to lock out machines or equipment for service or maintenance operations must be trained to recognize hazardous energy sources in the workplace, the type and magnitude of energy found in the workplace, and the means and methods of isolating and/or controlling energy as part of the facility’s lockout/tagout procedures.
Employees must be trained in the specific procedures for and the limitations of tagout systems. The standard also requires retraining all employees when new sources of hazardous energy are installed in the facility or updated lockout/tagout procedures are introduced, as well as providing regular retraining to maintain proficiency in lockout/tagout.
Along with developing, documenting, implementing, and enforcing lockout/tagout procedures in the facility, employers must ensure their workforce only uses the lockout/tagout devices authorized for the specific equipment or machinery in the facility. Lockout/tagout devices must be durable, standardized, and substantial. Devices must identify the individual who locked out or tagged out a machine or piece of equipment.
The employer also must ensure that any new or overhauled machinery or equipment is capable of being locked out. An effective tagout program must be developed, implemented, and enforced if machinery or equipment is incapable of being locked out.
Machine guarding protects machine operators and other employees in a work area from hazards created by ingoing nip points, rotating parts, flying chips, and sparks. Examples of machine guarding include barrier guards, light curtains, and two-hand operating devices. Machine guards must be attached to the machine where possible but may be attached elsewhere when guards cannot be attached directly to a machine.
Machines that pose an injury hazard to employees must be guarded, and the guarding device must conform to OSHA’s standard (§1910.212(a)(3)(ii)).
Where specification standards do not apply, the machine must be constructed to prevent the operator from having any part of his or her body in the danger zone during the machine’s operating cycle.
The area of a machine where work is performed is called the “point of operation.”
Machines requiring point-of-operation guarding include forming rolls and “calenders” that finish or smooth materials, guillotine cutters, jointers, milling machines, portable power saws and other power tools, power presses, shears, and alligator shears. Special hand tools used for placing and removing material from the point of operation must allow the operator to easily handle material without placing a hand in the danger zone.
Revolving barrels, containers, and drums must be guarded by an enclosure that interlocks with the drive mechanism so that the barrel, container, or drum cannot revolve unless the guard enclosure is in place.
Machine blades also must be guarded. The guard must not have openings larger than one-half inch. Machinery designed for a fixed location must be securely anchored to prevent the machine from “walking” or moving.
OSHA enforcement of the lockout/tagout and machine guarding standards remains robust. Violations can result in six- or even seven-figure fines and placement in OSHA’s Severe Violators Enforcement Program, with its mandatory follow-up inspections.
You want to have a strong compliance program for lockout/tagout and machine guarding. Neglecting machinery and equipment hazards could expose your employees to life-altering injuries.