OSHA is still fulfilling its mission promoting worker and workplace safety. Safety, Amputations, and Planned Inspections led the OSHA inspection categories for NAICS 332721 so far this year.
At PMPA we take a look twice a week at the OSHA inspections posted online for our industry. In the event that one of our members is on that list, we call immediately to offer our assistance. If it is a non-member, we look to learn what vulnerabilities are being encountered in the industry shops not belonging to PMPA.
Here’s what we found out.
So far this year, OSHA has posted notices of 53  inspections for our NAICS code- 332721 online. 53!

Chart of OSHA inspections frequency for 2018 NAICS 332721 Precision Machining Shops

 
The single largest category were for “Safety” – 15 of 53, 28% of all inspections posted.
Go figure.
The second most frequent category was “Amputations“-12 of 53, 23%.
This really is aggravating. There is no excuse for anyone to be losing body parts. We need to contact our people immediately to review the basics about pinchpoints, rotating equipment, and the pointlessness of trying to stop a lathe with our fingers or thumb. 
I won’t display the photos but if you want to see what a drill can do to a human hand click this link:  Graphic Image
Programmed (planned ) Inspections were third  with 7 of 53 or 13%. Routine enforcement is still a “real thing” at OSHA.
Complaints  came in at fourth  with 4 out of 53 inspections being initiated as a result of a complaint- 8% of inspections due to complaints..
Health tied with Complaints at 4 inspections out of 53- 8% of inspections due to occupational health concerns
Rounding out the ten causes were Noise, Reinspections, Accidents, Referrals, and Inspections.
Reasons cited for OSHA Inspections for NAICS 332721 (frequency) Calendar year 2018 YTD

 
OSHA is still fulfilling its mission promoting worker and workplace safety. The above reasons show how your peers are being examined. Are you ready for an OSHA inspection?
Photocredit: Mystalk
Data and Chart Preparation credit Veronica Hopson, PMPA
Original Data sourced from USDOL OSHA.

“The intent of this NEP is to target workplaces with machinery and equipment that cause (or are capable of causing) amputations, while maximizing the Agency’s inspection resources.”

OSHA Natiomnal Emphasis Program on Amputations 2015
OSHA updates NEP for amputations.

OSHA recently issued an updated National Emphasis Program (NEP) on Amputations. The NEP has been in existence since 2006 and is targeted to industries with high numbers and rates of amputations.
In this latest update NAICS code 332710 Machine Shops  and most other 332 NAICS code Categories are listed as Targets.
See Appendix C in the PDF
What else did we note when we looked at this?
-They will be asking for your DUNS Number
-They will be checking compliance on the new requirements for reporting work-related fatalities, hospitalizations, amputations, or losses of an eye.
Updated Directive
Change to Reporting requirements that went into effect January 1, 2015: Updated Employer Reporting Requirements 2015

If there is a worse combination than grinders and gloves, I don’t know what it is, except perhaps for gloves and a drill.
We posted a really cool video on our career blog about making a light saber sword here. But we were shocked to see the guys in the video wearing heavy leather gloves while working with grinders.

Never wear gloves with grinders.  or operate grinders with guards removed.
Never wear gloves with grinders. Or operate grinders with guards removed.

By “grinders,” we mean abrasive belt grinders, bench grinders, pedestal grinders, surface grinders, and also abrasive cutoff machines.
No Gloves!
No Gloves!

Sanders, polishers, and buffers that involve rotating wheels or transversing motion are also included in this classification for the purposes of hazard analysis.
Here are 6 reasons to not wear/not permit the wearing of gloves while working with Grinders or Grinding Machines

  • Amputations
  • General duty of employer to provide a workplace free of recognized hazards
  • Gloves can catch on rotating equipment and pull operators hands into the equipment
  • Rotation of grinding wheels is at high RPM’s
  • Operator cannot get hand out of glove when it catches
  • Equipment horsepower and machine material properties exceed those of the operators flesh

We did a quick calculation and a 12″ grinding wheel and 3600 rpm and arrived at a speed on the periphery of 120 miles per hour.
No time to react.
More info on preventing amputations from OSHA
 

 The Severe Violator Enforcement Program (SVEP) directive became effective on June 18.

"Do as I say, not as I do?"

(You wouldn’t know it from the OSHA website, they didn’t  provide either a date or directive number on their “directive.”  But negligence on their part on paperwork isn’t the crime that it is when employers make a paperwork omission…)

According to the  unnumbered, undated Directive posted on the website,   “This new directive establishes procedures and enforcement actions, including mandatory follow-up inspections and inspections of other worksites of the same company where similar hazards or deficiencies may be present. It replaces OSHA’s Enhanced Enforcement Program (EEP).”

“This Instruction establishes enforcement policies and procedures for OSHA’s Severe Violator Enforcement Program (SVEP), which concentrates resources on inspecting employers who have demonstrated indifference to their OSH Act obligations by committing willful, repeated, or failure-to-abate violations. Enforcement actions for severe violator cases include mandatory follow-up inspections, increased company/corporate awareness of OSHA enforcement, corporate-wide agreements, where appropriate, enhanced settlement provisions, and federal court enforcement under Section 11(b) of the OSH Act.”

What can trigger SVEP Status?
 Willful, repeated or failure-to-abate violations in one or more of the following circumstances:
A fatality or catastrophe situation
• Industry operations or processes that expose workers to severe occupational hazards
• Workers exposed to hazards related to the potential releases of highly hazardous chemicals
• Egregious enforcement actions

For our industry,  Falls (General Industry) and Amputations appear to be the primary categories  for awareness.
Here are the appropriate references for Fall Hazards, General Industry:
29 CFR §1910.23 – Guarding floor and wall openings and holes [Walking-Working Surfaces]
29 CFR §1910.28 – Safety requirements for scaffolding [Walking- Working Surfaces]
29 CFR §1910.29 – Manually propelled mobile ladder stands and scaffolds (towers) [Walking-Working Surfaces]
29 CFR §1910.66 – Powered platforms for building maintenance [Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms]
29 CFR §1910.67 – Vehicle-mounted elevating and rotating work platforms [Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms]
29 CFR §1910.68 – Manlifts [Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms]
For Amputations Information see this link: Amputations
And don’t expect any slack for paperwork omissions, like say, omitting a  directive control number or date on a record…

 

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Our industry doesn’t use “mechanical power presses” per se, but the OSHA Mechanical Power Press Standard, 29 CFR 1910.127 is often cited as governing our automatic cycling equipment.
Point of operation hazards are not just limited to power Presses, and may be found in our industry’s equipment as well.
The most common type of injury associated with mechanical power presses is amputation. Shouldn't have one of these showing up at your shop.
To reduce the frequency of occurrence of amputation injuries, OSHA has just published a new Safety and Health Information Bulletin on Hazards Associated with the “Unintended (Double) Cycling” of Mechanical Power Presses.
The references and bibliography may be of more than passing interest, especially if you have a power press somewhere in your operation as an ancillary operation.
If you have a number of these presses, YOU NEED THIS BULLETIN.
Even if you do not have “Mechanical Presses” in your shop, the OSHA etool found here will help you with safety in your shop.

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