Another Point of View About Safe Equipment

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Dennis Kaplan commented on Linked In about our Pedestal Grinder post from last week.

Like all critical thinkers, he reframed the question from “Why did it fail?” to “Why do we hold users accountable instead of certifying equipment like the Germans do?”

I have to admire his thinking- if the reason for OSHA is to make workplaces safer, why not start with a safe equipment certification program, rather than trying to ‘enforce’ compliance in hundreds of thousands of shops?

Thanks for sharing your thinking Dennis. Folks, here is Dennis’ response on PMPA LinkedIn group.

” Miles, I think it is even sadder that we can purchase items that are not OSHA safe to begin with.
Larger companies can afford to have a safety engineer.

“I think it isn’t fair to make a small machine shop responsible to keep up with all the regulations OSHA and other entities come up with. How do you expect a small shop with one owner and 1-2 employees to keep up with all the regulations. One day one solvent is okay next day it isn’t, but you can still purchase the stuff that isn’t okay to use. Even worst with equipment, you can buy a bench grinder, and then you still have to figure out how to make it OSHA safe. What’s up with that?

“The Germans have TÜV. Nothing can be sold in Germany that doesn’t pass TÜV. You buy something, you know it will pass all the regulations, all you have to do is keep the safety up.

“I have seen shops locked down because a manual milling machine didn’t have enough safety. Yet if you put all the safety they require on to the machine you wont be able to set the machine up, or make any parts. Who makes these rules anyway?
I think it is way more important to train the people in safety then making your machines idiot safe.”

Thanks again Dennis. We appreciate your sense making.

How Does The Universal Waste Rule Apply To Your Precision Machining Shop?

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Fluorescent light bulbs. Batteries.

These fall under the Category of Universal Waste.

While there may be state or local disposal requirements as well, in this post we’re going to address the federal requirements.

List of State Programs

Fluorescent Lamps

Fluorescent light bulbs save energy by producing more light for less wattage, requiring less energy and therefore less fuel burned.

However, the downside of this is the fact that these bulbs contain mercury, making disposal problematic. (When the mercury atoms are energized, they emit UV rays which cause the phosphors in the tube to glow (fluoresce)- producing visible light.)

Exposures to mercury can affect the human nervous system and harm the brain, heart, kidneys, lungs, and immune system.

The point is to minimize release of vapor that may contain Mercury. Here are 5 steps for handling fluorescent ‘s under Universal Waste rules:

Used lamps should be collected and packaged so as to minimize damage;
Employees should be trained on the hazards and procedures involving these type of “universal waste;”
Used lamps may be collected and stored on site for up to one year for recycling- Check your local regulations- they may be more stringent.
Shipments must be sent to a handler of universal waste or final recycling facility;
Businesses may not otherwise dispose of, mix with other waste or ‘treat’ mercury containing lamps.

Break one- here is what the EPA says you need to do for both CFL’s and Fluorescent tubes:

http://www.epa.gov/cfl/cflcleanup.html

Batteries

Contain any leakage in a container that will not react with nor release the contents.
Manage the waste in any way that is in compliance with applicable federal, state, and local regulations, if the waste is not hazardous.

Find battery recyclers near you.

Universal waste link: 40 CFR Part 273

List of State Programs

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Top 5 Precision Machining Websites

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Thanks Investment Tooling International Precision Toolmakers!

Was doing a random Google search the other day on the topic of precision machining.

Very pleased to find PMPASpeakingofPrecision named one of the 5 Top Precision Machining Websites by ITI Precision Toolmakers in Manchester England.

Thanks for the recommendation.

With over 130,000 page views and almost 300 views a day, PMPASpeakingOfPrecision has definitely become a web destination for precision machining topics and information.

And we have posts covering over 50 topics for which we come up Google Page One.

Thanks for the Recognition. And if we ever get over to your side of the pond, I think we’ll stop by to say Hi!

Bet we know who you folks root for in football.

Manchester United

Should the Unsafe Workers Job Be In Jeopardy Too?

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Tom Andel, Editor over at Penton’s Material Handling and Logistics blog, raised an interesting paradox the other day.

“Not only is it hard to recruit people into warehousing,” he says, ” but those who do get hired often exhibit an attitude problem about using personal protective equipment (PPE) like ear plugs or safety glasses. ”

2003_1028Beijing20157 — In the U.S. employers provide PPE...

Tom goes on to say “Al Will, who now trains young people in the ways of warehousing…followed up with me afterwards, adding: “It seems as though we’re in a Catch-22. If a company fires workers for PPE non compliance, they can’t readily find replacements.”

Hey Tom, we have the same situation going in Precision Machining and Manufacturing!

Back to Tom’s Post :”That’s why supervisors are sometimes lax in enforcing safety rules. Good material handlers are hard to find. One industry magazine article I read recently advocated a “take no prisoners” approach to safety enforcement:

“The rules are that a careless workman must be discharged and a foreman who keeps a careless operator, even though he be a good workman, lacks the discipline necessary to safely handle materials in a plant.”

“This article spread the blame for safety negligence in a plant across all functions: “the employer, for not having proper and sufficient equipment, the foreman for not properly instructing the workman, and the workman who does not complete his part of a task, as when he removes a barrel head and carelessly leaves nails protruding in the barrel.”

You can read the rest of Tom’s Blog post here.

What do you think? Are you a member of the “take no prisoners” camp? Or are you a member of the “we can even rehabilitate the folks we have to hire- they’re all we can get” School of Hard Knocks?

There is no doubt that OSHA holds the employer responsible for the safety of all employees.

So how do you solve this paradox?

Pedestal Grinders, OSHA, And You

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OSHA cited Advantage Powder Coating in Defiance, Ohio, for 15 safety violations and fined the company $159,600 after a pedestal grinder operator was killed when the abrasive wheel on the grinder exploded and struck the operator on the head.

pedgrind — Pay attention! This one can bite.

Two willful violations were cited for pedestal grinder violations:

Lack of properly adjusted safety guards;
Lack of properly adjusted work rests;

OSHA placed Advantage Powder Coating in its Severe Violator Enforcement Program (SVEP), which mandates targeted follow-up inspections to ensure compliance with the law. Advantage Powder Coating was placed in the program for receiving two willful violations covered under the agency’s National Emphasis Program on Amputations.

Pedestal grinders are a foundational piece of equipment in precision machining shops. It is up to us to assure that the potential hazards that they can present are controlled. Here are four tips from my experience to keep your shop grinders in compliance:

Don’t allow wheels to get out of dress.
Assure that the proper clearance and no more exists between properly dressed wheel and front tool rests
Assure that all grinders have all guards in place. If guards are missing- LOCK IT OUT!
Assure that the grinder is mounted to the floor if the pedestal was designed to be bolted to the floor. If no bolt holes are present, then bolting down is not necessary.

The safe use of grinders is a key part of our craft. It is up to us to keep the potential hazards that grinders can present safely controlled by insisting on safe grinder practices and inspections to assure guards are in place and properly adjusted.

Here is the news release

Grinder photo

5 Factors To Analyze Work

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Here are 5 factors to keep in mind when analyzing work.

Focus on the process. In my experience, it is seldom the people. If you start with the work instructions and compare to the process, you will find the answer.
Most waste comes from working on the wrong things. Are the activities being done actually adding value?
Classify the activities as definitely adding value, necessary, unnecessary, idle. Do everything in your power to eliminate all that do not add value.
Question “why?” for every activity that is being performed. Legacy is seldom worth paying for. How would a new startup today do this?
Communicate with everyone. Continuous improvement requires buy- in from the team, and their contributions may well out-value what an outside observer will develop.

Whether you use work sampling, just observation, time study, spaghetti diagram, flow charts, or notes scribbled on work instructions doesn’t really matter. The five points given above are the key to getting a savvy analysis of the job at hand.

18 Machine Safety Standards That You Might Need To Know

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Great sidebar in an article in Automation World. If you are doing or working with Machine Automation, this list is for you.

ISO 12100-1 and ISO 14121: Safety of machinery – principles for design and risk assessment
IEC 60204-1: Safety of electrical equipment
NFPA79 (2006): Electrical Standard for Industrial Machinery
ISO 13849-1, -2: Safety related parts of machinery (SRPCS)
IEC 61326-3-1: EMC and functional machinery
IEC 61508: Functional Safety (basic standard)
IEC61496: Safety
IEC61131-6: Safety for PLCs
IEC61800-5-2: Safety function for drives
IEC 61511: Standards for fire & gas systems
ANSI B11.19: Performance criteria for the design, construction, care and operation of safeguarding
ANSI B11.TR6: Safety control systems for machine tools
ANSI / RIA 15.06, CAN / CSA Z434: Safety requirements for robots and robot systems
IEC 62061: Functional safety of safety-related electrical, electric and programmable electronic control systems.

Standards for risk assessment

ANSI / RIA15.06, CAN / CSA Z434: Safety requirements for robots and robot systems
ANSI B11.TR3: Risk Assessment and risk reduction – A guide to estimate, evaluate and reduce risks associated with machine tools.
ANSI B11.2008: General safety requirements common to ANSI B11 machines.
ISO 14121: Safety of machinery – principles of risk assessment.

To read the feature article relating to this story, go to Feature Article

Weakest Growth Doesn’t Mean Weak Manufacturing

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The latest Institute for Supply Management Index for Manufacturing activity fell to 50.9 in July from 55.3 percent in June. The July reading was the lowest since the end of the recession in June 2009.

The important fact to know about the ISM numbers is that they indicate growth or contraction in manufacturing. For the past 23 months the index has shown that manufacturing has been expanding.

23 straight months of manufacturing expansion!

So the July 2011 data of 50.9 indicate that – guess what- manufacturing is still expanding, but just barely so. Why would we expect this to go on forever and ever?

After 23 straight months of expansion, a slow down in that expansion is hardly a sky is falling moment.

The PMPA’s Business Trends Sales Index is at its highest level at 131- with year 2008 as base year of 100.

Our latest data is strongly ‘remains the same’ or ‘positive’ so far.

So if you are one of the people wringing your hands over the <gasp> fact that after 23 straight months of expansion, the rate of growth and expansion in manufacturing might be slowing- well, here’s a nice cup of camomile tea.

There will be a blue sky up above you next month folks. One data point out of 23 is not reason to go to Defcon 1.

3 Facts About Scale (Iron Oxide) Rust On Steel

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On hot rolled bars to be cold drawn, the dark oxide surface is called scale.

bar coils — What we see on the surface is "scale"- a combination of oxides of iron.

Scale is the name given to the oxides of iron that are formed on as wrought products as a result of mill operations (high temperature rolling or furnace treatment)

Rust is the commonly used term for iron oxide from weathering or corrosion.

Scale is

Hard
Brittle
High Coefficient of Friction

So we need to get it off the steel if you are to have any chance of keeping the tool edge sharp.

There are 3 oxides of iron:

Hematite ( Fe₂ O₃) has a microhardness of ~ 1030 D.P.H., is red in color, and is not soluble in acid.

Magnetite (Fe₃O₄) has a microhardness of ~ 420-500 D.P.H., is black in color, and is not soluble in acid.

Wustite (FeO) has a microhardness of ~ 270 -350 D.P.H., is blueish in color, and is soluble in acid. Wustite is the phase that makes up the innermost scale on the bars or rods.

Hematite and Magnetite make up the outer layers of the scale, and due to their composition, make up the larger mass of scale present. Due to their hardness and quantity they are the real dealbreakers for machining as they create tool edge wear.

One of the ways that Cold Finished Steel bars aid machinability is by removing these hard abrasive oxides from the workpiece, so that they don’t destroy your tools and contaminate your cutting fluids.

Bar Coils

Some Deal! Kicking the Can With Invisible Spending Cuts

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The much awaited Budget deal is sure to disappoint anyone expecting real help for the budget, deficit, or the country.

The spending cuts don’t even arrive immediately, instead they are implemented over a period of years- just $2.4 trillion over a decade.

So much for urgency, seriousness, or responsibility.

The bulk of those cuts have not been identified- kicked down the road to a future Congressional Commission.

All this deal does is kick the real work of building a responsible budget down the road past the 2012 elections.

When are savings not savings?

When they are promised but never achieved.

Kick The Can

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