Issue link: http://palletcentral.uberflip.com/i/536121
palletcentral.com PalletCentral • July-August 2015 25 There are a variety of types of sawing equipment used in the pallet industry sector, including band saws and re-saws, circular saws, table saws and radial arm saws. While some of this equipment comes equipped with manufacturer-installed guards, others are not designed in this manner because of feasibility issues. Sometimes, OSHA will challenge pallet companies to design their own guards, but installing fabricated guards can itself interfere with the safe or efficient operation of the equipment and—moreover—can invalidate a manufacturer's warranty because the pallet company has, in effect, "redesigned" the equipment and therefore assumes more liability for its failure or misuse. When approaching OSHA on this issue in the previous administration, NWPCA took the position that, by following recommended "best practices," employees can work safely around such potentially hazardous equipment without installing point-of-contact guards. After development of the best practices through the previous OSHA/NWPCA alliance, the salvo of citations ceased for the most part but, in the current administration, isolated enforcement actions have occurred concerning equipment such as dismantling machinery under one of OSHA's machine guarding standards (e.g., 29 CFR 1910.212 and 1910.213). Generally, the matters have been resolved without the need for litigation or modification of equipment, but employers are well- served if they are familiar with these safety "SOPs" in advance of an OSHA visit, train employees on the safe work practices, and OSHA's preference is always going to be to install guards on the equipment to prevent contact with mechanical motion hazards, but inspectors can be convinced not to issue citations if they are satisfied with work procedures that can satisfactorily protect workers.